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provide over one half of the cost of maintaining such a
household.
During the years in question, petitioner lived in her home
with Char Nea and Shauneille. The Court has held that petitioner
failed to prove she contributed more than one half of Char Nea's
support for any of the years at issue; thus, she is not entitled
to a dependency exemption for Char Nea for any of those years.
Moreover, petitioner conceded that she is not entitled to
dependency exemptions for Shauneille for 1990 and 1991, and she
did not claim them for 1989 and 1992. Consequently, neither Char
Nea nor Shauneille can be considered as qualifying dependents for
purposes of section 2(b). Likewise, petitioner failed to prove
she provided over one half of the cost of maintaining a household
for any other qualifying dependent.
On this record, the Court holds that petitioner is not
entitled to head-of-household filing status for any of the years
at issue. Respondent is, therefore, sustained on this issue.
The fourth issue is whether petitioner is entitled to a
casualty loss deduction, under section 165(a), in the amount of
$5,039 for 1989. On her income tax return for 1989, petitioner
included five Forms 4684, Casualties and Thefts, pursuant to
which she claimed casualty losses of $6,488. After application
of the 10-percent adjusted gross income floor, the amount of the
loss, $4,389, was carried over to Schedule A, Itemized
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