Darrell D. Reed - Page 7




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          Commissioner, 99 T.C. 202, 212 (1992).                                      
               Furthermore, it is reasonable to infer that Ms. Hunter may             
          have contributed a modicum amount to the support of her children.           
          Ms. Hunter received public assistance during the years in issue,            
          and without these amounts or additional amounts she may have                
          received from her extended family we are unable to determine the            
          total support available to the children by all able parties.  Ms.           
          Hunter did not testify at trial.                                            
               By failing to establish the total amount of support provided           
          to the children from all sources, including Ms. Hunter’s public             
          assistance, we are unable to conclude that petitioner provided              
          more than one-half of the children’s total support during the               
          years in issue.  Furthermore, as to Mr. Elms, there is no                   
          corroborating evidence to substantiate petitioner’s claimed                 
          dependency deduction.  Therefore, we hold that petitioner is not            
          entitled to section 151 dependency exemption deductions for the             
          1995 and 1996 tax years.  Respondent is sustained on this issue.            
          Head of Household Status                                                    
               According to the relevant part of section 2(b), an                     
          individual shall be considered a head of household if such                  
          individual (1) is not married at the close of the taxable year              
          and (2) maintains as his home a household which constitutes for             
          more than one-half of the taxable year the principal place of               
          abode of an individual who is a dependent of the taxpayer, if the           





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