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We are unable to accept petitioner’s testimony for a
variety of reasons, among them the following three: First,
petitioner introduced no documentary evidence to support his
testimony.7 Second, we do not think that a U.S. consular office
would issue six SSNs that had already been assigned to other
individuals. Third, we do not think that SSNs would be assigned
to nonresident foreign nationals who are not employed in the
United States or not otherwise legally in the United States for a
valid nonwork purpose. In this regard, see 20 C.F.R. sec.
422.104(a)(2), (3), 422.107(a), (e) (2000).
In view of the foregoing, we hold that section 151(e) bars
allowance of deductions for dependency exemptions for
petitioner’s relatives on petitioner’s 1996 and 1997 income tax
returns. Respondent’s determination in this regard is therefore
sustained.
Issue (2): Filing Status
Petitioner designated his filing status as head of household
on his 1996 and 1997 income tax returns.
As relevant herein, a taxpayer is considered a head of
household if either (1) the taxpayer maintains as his or her home
a household that constitutes, for more than one-half of the
7 Petitioner did offer one exhibit in support of his
testimony, but it was not admitted into evidence because (inter
alia) it was incomplete on its face, it was not authenticated,
and it was hearsay (and there were no circumstantial guaranties
of trustworthiness or other applicable hearsay exception).
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