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providing their support” whether they were in custody, or at a
foster or group home. Jamar, according to petitioner, stayed
with his aunt, Katherine Swayzer, and with petitioner. He stayed
with his aunt so that “he could go to a particular school”.
Petitioner submitted copies of miscellaneous receipts and
invoices for a variety of items including drycleaning bills,
invoices for storage payments, motel receipts, grocery receipts,
Lotto receipts, and receipts for pet supplies and other items.
Almost all the receipts and invoices were in the name of “James
E. Daniels”. There is evidence of the payment of auto insurance
and registration of an automobile in the joint names of James and
Jamar Briggs, but Jamar (Briggs) Daniels was not able to legally
drive until December of 1996. There is nothing in the record,
however, to indicate that petitioner provided over half the cost
of maintaining as his home a household that for more than one-
half the year was any of his sons’ principal place of abode in
1995 or 1996.
Petitioner has not shown that he qualifies for head of
household filing status for either year in suit, and respondent’s
determination on this issue is sustained.
Dependency Exemptions
Section 151(c)(1) allows a taxpayer to claim an exemption
deduction for each qualifying dependent. A child of the taxpayer
is considered a “dependent” so long as the child has not attained
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