Irene E. Jones, a.k.a. Irene E. Perry-Jones a.k.a. Irene E. Perry - Page 16

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          estimate the amount of time that her daughter Melanie and her               
          granddaughter Nicole lived with her, her response was that they             
          lived with her only about one-half of the time during 1993 and              
          1994.  The record shows that petitioner's daughter Melanie lived            
          in an apartment provided by PHA throughout 1993 and 1994.                   
          Petitioner has testified that Melanie was involved in an abusive            
          relationship during those years and sometimes sought refuge at              
          petitioner's home for a month or more at a time.  But the                   
          apartment always was provided for Melanie and Nicole by PHA                 
          during the years in issue and was available to them.  Although              
          Melanie and Nicole may have lived with petitioner on and off                
          during the years in issue, we hold on this record that petitioner           
          has failed to prove that she provided their principal place of              
          abode for more than half of the taxable years 1993 and 1994.                
          Accordingly, petitioner has not qualified for head of household             
          status under section 2(b) for 1993 and 1994.                                
               Additionally, section 2(b) requires that a taxpayer not be             
          married at the close of the taxable year to qualify for head of             
          household filing status.  Petitioner married Mr. Jones in August            
          1994, and there is no indication in the record that she and Mr.             
          Jones were separated at the end of 1994, or that they lived apart           
          during the last 6 months of that year.  See secs. 2(b)(2),                  
          7703(b).  According to the plain language of the statute, in                
          order to be eligible for head of household filing status, a                 





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