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paid by petitioner's brother, with help from the Government.
Without proper substantiation, the Court cannot conclude from the
record that more than one-half of the support of each claimed
dependent was provided by petitioner. Thus, petitioner has
failed to establish that he provided over half of the total
support for Melissa and Omar. Accordingly, we hold that
petitioner is not entitled to claim his niece and nephew as
dependents under section 151.
Respondent determined that petitioner's filing status should
be changed from head of household to single. Section 2(b), in
relevant part, defines head of household as an unmarried taxpayer
who maintains as his home a household which constitutes for more
than one-half of such taxable year the principal place of abode
of a person who is a dependent of the taxpayer, if the taxpayer
is entitled to a deduction for the taxable year for such person
under section 151. Sec. 2(b)(1)(A)(ii). Because we held that
petitioner is not entitled to a deduction for either his niece or
his nephew in 1998 under section 151, we also hold that
petitioner may not claim head of household filing status. We
sustain respondent's determination as to this issue.
Petitioner claimed a credit for child and dependent care
expenses of $566 for 1998, which respondent disallowed. Section
21 provides, in part, that an individual who maintains a
household which includes as a member a qualifying individual
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