Audrey A. Carlisle - Page 4

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          Anaheim apartment often.  At that time, Corey was enrolled in               
          Stoddard Elementary School in Anaheim.  All report cards were               
          signed by Ms. White as Corey’s parent or legal guardian.  The               
          Whites and Corey moved to Rouses Point, New York, in September              
          1996 to be with Ms. White’s sister who was diagnosed with cancer.           
          Corey was enrolled into Rouses Point Elementary School on October           
          1, 1996.                                                                    
               After Corey and the Whites moved to Rouses Point, petitioner           
          sent approximately $150 per month for Corey’s support.  Corey               
          wrote petitioner often and informed petitioner of items he wanted           
          or needed, e.g., ice skates for hockey, video games, and                    
          clothing.  Petitioner shipped these items directly to Corey.                
               On petitioner’s 1996 Federal income tax return, petitioner             
          reported wages of $14,066.  She also claimed a dependency                   
          exemption deduction for Corey and an earned income credit.                  
          Respondent disallowed the dependency exemption because petitioner           
          failed to establish that she was entitled to the exemption.                 
          Respondent further determined that petitioner was not entitled to           
          the earned income credit.                                                   
          Dependency Exemption                                                        
               Section 151(c) allows a taxpayer to deduct an annual                   
          exemption amount for each child under the age of 19 who is a                
          dependent of the taxpayer.  A “dependent” is defined in section             
          152(a) as an individual “over half of whose support, for the                

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