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did not maintain a household in either year. Having concluded
Gabriel is not entitled to dependency exemptions for his father
under section 151 in 1995 or 1996, we hold that Gabriel is not
entitled to head of household filing status in either year.
With respect to Morhaf, respondent concedes that he provided
more than one-half of the support in 1995 for his mother within
the meaning of section 1.152-1(a)(2)(i), Income Tax Regs., and as
such is entitled to a dependency exemption deduction for her.
Respondent, however, maintains that Morhaf is not entitled to head
of household filing status in 1995 because he has not established
that he paid more than half of the expenses of maintaining a
household for his mother.
To determine whether Morhaf maintained a household for Laila
in 1995, we first must decide what constituted Laila’s household.
Petitioners argue that there were two separate households within
the Foster City residence during 1995 and 1996: One consisting of
Gabriel and Mahmoud and one consisting of Morhaf and Laila.19
Although respondent agrees that it is possible for two separate
households to exist under one roof, respondent argues that the
members of the Mahmoud Daya family were all part of one household
in 1995 and 1996.
19 Although Mayar resided at the Foster City residence
during 1995 and 1996, petitioners have not indicated of which
household he was a member.
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