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deduction for Ayla, a child care expense credit, and an earned
income credit for each of the tax years 1997 and 1998.
Respondent issued a notice of deficiency for each of the
years 1997 and 1998. Respondent disallowed the claimed
dependency exemption deduction for each of the tax years on the
basis that petitioner failed to establish that she provided more
than one-half of Ayla’s support. Respondent disallowed the
claimed head-of-household filing status on the basis that
petitioner failed to establish that she paid more than one-half
of the household expenses. Respondent disallowed petitioner’s
child care credit for each of the years in issue because
petitioner failed to establish that she maintained a household
and failed to substantiate the amounts paid.1 Finally,
respondent disallowed petitioner’s earned income credit for each
of the years in issue on the ground that the Stephans’ modified
adjusted gross income was higher than petitioner’s in both 1997
and 1998.
The first issue for our consideration is whether petitioner
is entitled to a dependency exemption deduction for Ayla for each
of the years in issue. A taxpayer is allowed a deduction for a
dependent, such as a daughter, for whom the taxpayer has provided
over one-half of her support. Secs. 151(a), (c), and 152(a).
1 Respondent conceded that petitioner substantiated
payments for child care in the amounts of $901 for 1997 and $275
for 1998.
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