Joann S. Allen - Page 6




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          clothing, education, medical treatment, vacations, life                     
          insurance, and transportation.  Id.                                         
               Petitioner’s children each received funds from Social                  
          Security, and Mr. Allen purchased food for the household.                   
          Considering these funds were available for support of the                   
          household, we conclude that petitioner did not furnish over half            
          the cost of maintaining the household.  Therefore, we sustain               
          respondent’s determination.                                                 
               2. Earned Income Credit                                                
               On her 1996 income tax return, petitioner claimed an earned            
          income credit.  In the case of an eligible individual, section              
          32(a) allows an earned income credit against the individual’s               
          income tax liability.  As relevant herein, an “eligible                     
          individual” is defined as an individual who has a “qualifying               
          child” for the taxable year.  Sec. 32(c)(1)(A).                             
               The record reflects that each of petitioner’s sons qualifies           
          as a “qualifying child” pursuant to the requirements set forth in           
          section 32(c)(3)(A)(i through iv).  In this regard, each of the             
          three sons satisfies the relationship test, see sec.                        
          32(c)(3)(A)(i) and (B)(i)(I), the residency test, see sec.                  
          32(c)(3)(A)(ii), and the age test, see sec. 32(c)(3)(A)(iii) and            
          (C)(i).  Finally, petitioner satisfied the identification                   
          requirement under section 32(c)(3)(C)(A)(iv) and (D)(i) for each            
          of the three children.                                                      






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