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increased to $32,000 per year, and Mendy has stopped receiving
welfare benefits.
Petitioner timely filed a Federal income tax return as a
head of household in each of the years in issue. In 1995, he
reported income of $8,590, claimed exemption deductions for
himself, Dustin, and Kristion, and claimed the earned income
credit with Dustin and Kristion as qualifying children. In 1996,
he reported income of $8,761, claimed exemption deductions for
himself, Kristion, and Brittany, and claimed the earned income
credit with Kristion and Brittany as qualifying children. In the
statutory notices of deficiency, respondent for each year changed
petitioner’s filing status to single and disallowed the
dependency exemption deductions and earned income credit.
Subject to limitations not applicable here, a deduction is
allowed under section 151(a) for each dependent of a taxpayer.
Sec. 151(a), (c)(1). A child of the taxpayer, or an individual
whose principal place of abode is the taxpayer’s home and who is
a member of the taxpayer’s household, is a dependent of that
taxpayer if the taxpayer provides over half of his support for
the taxable year. Sec. 152(a)(1), (9).
Respondent makes several arguments supporting his
disallowance of the claimed dependency exemption deductions.
First, as to Dustin and Kristion, respondent argues that
petitioner is not their father. However, a taxpayer need not be
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