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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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