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Regs. Support also includes public assistance, such as welfare
and food stamps, received by the individual. These items are
calculated as part of the total amount of support received by the
individual and are not attributed to the taxpayer. See Gulvin v.
Commissioner, 644 F.2d 2, 3 (5th Cir. 1981), affg. T.C. Memo.
1980-111; Smith v. Commissioner, supra.
Petitioner failed to establish that she provided more than
one-half of Simeon’s support. We are unsure as to the total
amount of support Simeon received from all sources. The record
is also silent as to the amount of support Simeon received from
petitioner. Therefore, we sustain respondent’s determination.
2. Filing Status
In order to qualify for head-of-household filing status, a
taxpayer must satisfy the requirements of section 2(b). Pursuant
to that section, and as relevant herein, an individual qualifies
as a head of household if the individual is not married at the
close of the taxable year and maintains as her home a household
that constitutes for more than one-half of the taxable year, the
principal place of abode of a son or daughter of the taxpayer.
Sec. 2(b)(1)(A)(i). A taxpayer is considered as maintaining a
household only if more than half of the cost of maintaining the
household during the taxable year is furnished by the taxpayer.
Petitioner was not married at the close of 1998. Simeon
lived with petitioner for the entire year at issue. However,
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