John S. Turay - Page 3




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          him for 12 months in 1995. However, petitioner calculated the               
          total number of dependents claimed on his return and indicated              
          that, of the four claimed dependents reported, three resided with           
          him and one did not. Petitioner claimed head-of-household filing            
          status and a dependent care credit in the amount of $1,008.                 
               Petitioner's daughter, Mariatu, was 23 years of age in 1995.           
          Mariatu left Africa subsequent to her mother's death and came to            
          reside in the United States in 1988.  Mariatu was a resident of             
          the United States in 1995.  Three separate addresses for                    
          Mariatu's residence were reported to respondent by means of Forms           
          W-2, and Mariatu's filed Federal income tax return for the 1995             
          tax year.  One such address provided on the Form W-2 was that of            
          petitioner's residence.  Mariatu received wages in 1995 in the              
          amount of $14,697 which she reported on her Federal income tax              
          return for that year.  Also on her return, Mariatu claimed an               
          exemption for herself and a dependency exemption deduction for a            
          child listed as her stepdaughter.  She also claimed single filing           
          status.                                                                     
               Petitioner's niece, Isatu, was approximately 23 and 24 years           
          of age in 1995 and 1996, respectively.  Sometime prior to the               
          years in issue, Isatu left Africa to reside in the United States.           
          She was a resident of the United States during the years in                 
          issue.  Four separate addresses for Isatu were reported to                  






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