Robert Cotton, Jr. - Page 5




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          with petitioners between 1994 and 1996.  Shirleetta Douglas’                
          residence was located in the same neighborhood as petitioners’              
          residence.  Jerome Douglas also lived with Shirleetta Douglas               
          during the period at issue.  Shirleetta Douglas’ children,                  
          Shaquita and Kevin Douglas, occasionally lived with petitioners             
          between 1994 and 1996.  Eula Cotton (Mr. Cotton’s sister), Kevin            
          Cotton, Starlesha Cotton, Maurice Cotton, and Johnny Gray (Mr.              
          Cotton’s nephews and niece) intermittently lived with petitioners           
          during the period at issue.  None of the claimed dependents, with           
          the exception of Samuel Douglas, lived with petitioners for an              
          entire year, and each of the claimed dependents lived with                  
          petitioners for 6 months or less per year.                                  
               Samuel Douglas worked in 1996 and received wages.5                     
          Shirleetta Douglas received “Section 8" housing during the period           
          at issue.  Petitioners purchased groceries for the household.               
          Petitioners took the children to school, but petitioners did not            
          purchase clothing or pay for any other expenses for the claimed             
          dependents.                                                                 
               Petitioners filed separate Federal income tax returns for              
          the years in issue.  Mr. Cotton, on his 1994, 1995, and 1996                
          Federal income tax returns, and Mrs. Cotton, on her 1994 and 1996           



               5    The amount received has not been made part of the                 
          record.                                                                     





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