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from the fathers of her children during 1995. Ms. Froemel did
not work while she lived with petitioner.
Petitioner's rent for his apartment during 1995 was $635 per
month. Ms. Froemel contributed $300 per month toward the rent.
She used her monthly food stamps to buy groceries for the
apartment. Petitioner paid for all of the other household
expenses. He also paid for Joshua's and Amber's clothing during
1995.
The first issue for decision is whether petitioner is
entitled to dependency exemption deductions. On his 1995 return,
petitioner claimed dependency exemption deductions for Ms.
Froemel, Joshua, and Amber. In the statutory notice of
deficiency, respondent disallowed the claimed deductions.
An individual taxpayer is allowed as a deduction in
computing taxable income an additional exemption for each
dependent as defined in section 152. See sec. 151(c)(1). A
dependent is generally defined as an individual who receives over
half of his support from the taxpayer in the calendar year in
which the taxpayer's taxable year begins. See sec. 152(a).
Individuals listed under this general definition include, among
others, an individual who for the taxable year of the taxpayer
has as his principal place of abode the home of the taxpayer and
is a member of the taxpayer's household. See sec. 152(a)(9).
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