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for more than one-half the year was his child’s or children’s
principal place of abode. Sec. 2(b)(1).
Petitioner did not submit any evidence to prove that in
either 1997 or 1998 he provided over half the cost of maintaining
as his home a household that for more than one-half the year was
the principal place of abode of any of his three sons.
Petitioner has not shown that he qualifies for head of household
filing status for 1997 or 1998. Respondent’s determination is
sustained.
Issue 2. Dependency Exemptions
Petitioner claimed dependency exemption deductions for his
three sons for 1997 and 1998. Section 151(c)(1)(B) allows a
dependency exemption deduction for each child of the taxpayer so
long as the child has not attained age 19 (24 if the child is a
student) at the close of the taxable year and more than half of
the child’s support for the taxable year was received from the
taxpayer. Sec. 152(a). In order for petitioner to establish
that he provided more than half of the support for any of his
sons, he must show by competent evidence the total support
furnished for each of them from all sources during the years at
issue. Blanco v. Commissioner, 56 T.C. 512, 514 (1971).
Petitioner introduced no evidence of the total support furnished
for each of his sons from all sources for either of the years at
issue. Moreover, it appears from the judgment of the Superior
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