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to claim a dependency exemption deduction for Maddison under
section 151(c) in accordance with section 152(e)(2). It does not
provide petitioner with the right to claim head-of-household
filing status and the earned income credit. In order to claim
head-of-household filing status and the earned income credit,
petitioner must satisfy all of the statutory requirements under
sections 2(b) and 32, respectively. We note that respondent did
not disallow petitioner's claimed dependency exemption deduction,
nor is petitioner being penalized for his misunderstanding
inasmuch as respondent did not determine any penalties.
Petitioner filed in the manner he did based on his
understanding of the divorce decree provision allowing him to
claim Maddison as his dependent. Nevertheless, both section 2(b)
and section 32 require that petitioner's household be Maddison's
principal place of abode for more than one-half of the taxable
year. Although Maddison resided with him for part of each year,
this does not satisfy the requirement that they had the same
principal place of abode for more than one-half of each taxable
year. Accordingly, we sustain respondent's determination.
To the extent that we have not addressed any of the parties'
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