Audrey A. Carlisle - Page 6

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          not entitled to a section 151 dependency exemption deduction for            
          the 1996 tax year.  Respondent is sustained on this issue.                  
          Earned Income Credit                                                        
               The relevant parts of section 32 provide that an individual            
          is eligible for the earned income credit if the individual has a            
          qualifying child.  A “qualifying child” is a son or daughter of             
          the taxpayer who has not attained the age of 19 at the end of the           
          taxable year and shares the same principal place of abode in the            
          United States with the taxpayer for more than one-half of the               
          taxable year.                                                               
               Corey was a minor at the end of 1996, and, therefore, meets            
          the age requirement of section 32.  However, petitioner lived               
          with Corey from January through May of 1996, then moved into her            
          own apartment.  Because Corey resided with her for less than one-           
          half of 1996, petitioner fails to meet the time period                      
          requirement of section 32.  Respondent is sustained on this                 
               Reviewed and adopted as the report of the Small Tax Case               
                                                  Decision will be entered            
                                             for respondent.                          

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