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Accordingly, we sustain respondent's determination that
petitioner is not entitled to a dependency exemption deduction
for Amanda in 1998.
2. Head of Household Filing Status
Respondent determined petitioner’s filing status to be
single rather than head of household for 1998 because Amanda did
not reside with petitioner for more than one-half of the year.
Section 1(b) imposes a special tax rate on individuals
filing as head of household. As relevant herein, head of
household is defined in section 2(b) as an unmarried individual
who maintains his home as the principal place of abode for a son
or daughter for more than half of the taxable year.
Petitioner has not demonstrated that he maintained such a
household. Petitioner’s own testimony indicated that he failed
to maintain a principal place of abode for Amanda for more than
one-half of 1998: “From January 1st until [the middle of] June
1998." To qualify, petitioner needed to prove, at a minimum,
that he provided the principal place of abode for Amanda from
January 1 until July 2, 1998. He testified further that Amanda
did not stay at his house more than half of the week during that
period. He acknowledged that during the periods of the year
where Amanda did not reside at his abode, she stayed with Ms.
Macera. Furthermore, petitioner failed to present any evidence
in addition to his own testimony regarding his entitlement to
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