- 6 - Petitioner testified that he and Krissa Williams lived at 9908 Independence from January until May 1997. Petitioner provided no evidence of his contributions toward maintaining this household. According to petitioner, Krissa Williams did not live with him during the summer months, and it was not until October 1997 that Krissa Williams resumed her residence with petitioner. Petitioner testified that in October 1997 he and Krissa Williams moved into a home at 27 Windsor Drive, which petitioner testified he eventually purchased under a rent-to-buy agreement. Even if petitioner incurred the entire cost of maintaining his household at 27 Windsor Drive, he maintained this household for only the last 3 months of the year. We cannot presume that these expenses exceeded one-half of the cost of maintaining Krissa Williams' principal abode for the year. We have no doubt that petitioner contributed to the care of Krissa Williams. In fact respondent did not make an adjustment with respect to petitioner's dependency exemption for Krissa Williams. The regulations, however, specifically provide that the costs of maintaining a household "do not include the cost of clothing, education, medical treatment, vacations, life insurance, and transportation." Sec. 1.7703-1(b)(4), Income Tax Regs. Without evidence of the cost of maintaining a household or of petitioner's contributions, it is impossible to conclude that petitioner provided more than one-half of the cost of maintainingPage: Previous 1 2 3 4 5 6 7 Next
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