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Petitioner listed his filing status as a head of household
on his Federal income tax return for each year in issue. He did
not elect to itemize deductions for either year. Relevant for
our purposes, on each return he claimed a dependency exemption
deduction for each of his children and an earned income credit.
Petitioner computed the earned income credit claimed on each
return by treating two of his children as “qualifying” children.
Delores Hamilton did not file a Federal income tax return
for any year in issue. For each year she signed a Form 8332,
Release of Claim to Exemption for Child of Divorced or Separated
Parents.
In the notice of deficiency for each year, respondent
changed petitioner’s filing status from head of household to
single and reduced the standard deduction accordingly.
Respondent also disallowed all of the claimed dependency
exemption deductions and the earned income credit. No
explanations for the adjustments were included in the notices of
deficiency.
OPINION
I. Dependency Exemption Deductions
Generally, section 151(c) allows a taxpayer a dependency
exemption deduction for each dependent as defined in section 152.
The term "dependent" includes certain individuals, such as a son
or daughter, "over half of whose support, for the calendar year
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