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petitioner’s mother, and petitioner’s brother. Taking into
account petitioner’s income, the amount of his brother’s income,
the amount of Social Security benefits received by petitioner’s
mother, and the fact that petitioner’s nephews lived in
petitioner’s mother’s house, it is unlikely that petitioner
contributed more towards the support of his nephews than the
combined contributions of his mother and brother. Although
petitioner generously provided food, clothing, and other items of
support for his nephews during 1997, he failed to establish that
the total amount of the support that he provided exceeded the
support his nephews received from other sources; namely, his
brother, his mother and, with respect to two of them, themselves.
Consequently, petitioner is not entitled to dependency exemption
deductions for his nephews, and respondent’s determination in
this regard is sustained.
2. Filing Status
Petitioner filed his 1997 return as a head of household.
Under the circumstances, because petitioner is not entitled to a
dependency exemption deduction for at least one of his nephews,
he does not qualify as a head of household. Sec. 2(b)(1)(A)(ii).
Respondent’s determination changing his filing status from head
of household to single is sustained.
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Last modified: May 25, 2011