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In the statutory notice of deficiency, respondent changed
petitioner’s filing status to single, disallowed the dependency
exemption deductions, and disallowed the earned income credit.
The first issue for decision is whether petitioner is
entitled to two dependency exemption deductions.
Subject to various exceptions and limitations not applicable
here, a deduction generally may be allowed under section 151(a)
for each dependent of a taxpayer. Sec. 151(a), (c)(1). A
taxpayer’s niece or nephew generally is a dependent of the
taxpayer only if the taxpayer provides over half of the niece’s
or nephew’s support for the taxable year. Sec. 152(a)(6).
We are convinced that, during most of 1998, petitioner paid
various expenses for the children and had significant
responsibility in caring for them. However, petitioner has
failed to provide the Court with any significant corroborative
evidence showing that he provided over half their support during
that year. A major component of the children’s support was their
housing, but because petitioner was residing in his sister’s
apartment for which he paid no rent, the rental charge for the
apartment was provided by a source other than petitioner. See
sec. 1.152-1(a)(2)(i), Income Tax Regs. Furthermore, petitioner
only resided with Brianna and Cody for 9 to 10 months during
1998, and presumably was providing for none of their support
during the remaining 2 to 3 months. Based on the record before
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