Audrey A. Carlisle - Page 3

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               Respondent determined a deficiency in petitioner’s Federal             
          income tax for 1996 in the amount of $2,162.  The issues for                
          decision are:  (1) Whether petitioner is entitled to a dependency           
          exemption deduction for her son; and (2) whether petitioner is              
          entitled to an earned income credit.  At the time the petition              
          was filed, petitioner lived in Fullerton, California.                       
               Petitioner has a minor son, Corey Lewis (Corey), born on               
          October 11, 1987.  On July 17, 1991, Annjeannette Lee White (Ms.            
          White) was appointed guardian of Corey, and received letters of             
          guardianship from the Orange County Superior Court.                         
               From January through May of 1996, petitioner and Corey lived           
          with Ms. White, her husband Albert White (Mr. White) and their              
          adult son, Clarence White (Clarence) (collectively the Whites),             
          in a 2-bedroom apartment in Anaheim, California (Anaheim                    
          apartment).  The apartment also had a kitchen, dining/living                
          room, and backyard.  Petitioner paid $300 in cash directly to Ms.           
          White as her monthly contribution towards rent, utilities, and              
          food.  The Anaheim apartment lease was in Mr. and Ms. White’s               
          names, with a monthly rent of $740.  Ms. White did the grocery              
          shopping and cooking for the household.  Ms. White also purchased           
          all of Corey’s clothing during the year in issue.                           
               In June, petitioner moved to a 1-bedroom apartment in Buena            
          Park, California.  Corey remained with the Whites at the Anaheim            
          apartment.  Petitioner visited Corey and the Whites at the                  

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