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In separate notices, respondent determined deficiencies in
petitioner’s income taxes based on the following adjustments for
each of the years in issue: (1) Respondent changed petitioner’s
filing status from head-of-household to single; (2) respondent
disallowed the dependency exemptions claimed by petitioner; and
(3) respondent disallowed the earned income credit claimed by
petitioner.
Discussion
Before deciding the substantive issues before us, we think
that a preliminary comment is in order.
At trial, petitioner testified in her own behalf.
Respondent’s counsel cross-examined petitioner and also called
two third-party witnesses. We found petitioner to be a credible
witness, and we have relied heavily on her testimony in making
our findings.
We turn now to the substantive issues before us.
A. Filing Status
As relevant herein, an individual qualifies as a head of a
household if such individual is not married at the close of her
taxable year3 and maintains as her home a household that
constitutes for more than one-half of such taxable year the
3 Respondent, by determining petitioner’s filing status to
be single for each of the years in issue, has implicitly conceded
that petitioner was not married at the close of any of those
years. See sec. 1(c); see also secs. 2(c); 7703(b).
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