Leona Payton - Page 4

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          as needed, a number of individuals, mostly family members, with             
          food, clothing, shelter, and on some occasions, with financial              
          aid.  Petitioner is a licensed practical nurse and worked full-             
          time at South Point Hospital during the years in issue.                     
               After the death of petitioner’s mother, Mattie Barnes (Ms.             
          Barnes), in January 1996,  Areail Pruitt2 (Areail), petitioner’s            
          youngest sister, had difficulties coping with the loss of their             
          mother.  Areail’s children, petitioner’s niece and nephew,                  
          Racquelle Givens (Racquelle) and Rafael Givens (Rafael),                    
          respectively, stayed with petitioner from the time of Ms. Barnes’           
          death until after completion of the school year in June 1996.               
          Both Racquelle and Rafael were minors during the years in issue.            
               Petitioner’s older brother, Preather Pruitt (Preather), age            
          41 in 1995, had undergone 2 heart surgeries prior to 1995 and was           
          disabled during the years in issue.  He lived in his own                    
          apartment but could not work due to his disability.  He received            
          approximately $400 per month as disability payment from his                 
          former employer.  Preather’s monthly rent was approximately $300            
          per month which did not include utility expenses.  Petitioner               
          frequently assisted Preather financially.  In 1996, Preather                
          received Medicaid benefits in addition to the $400 monthly                  

               2    The family name “Pruitt” is spelled “Preuitt” on                  
          petitioner’s 1997 Federal income tax return.  For consistency, we           
          shall use the “Pruitt” spelling for purposes of this opinion.               

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