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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 maintaining
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