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they did not otherwise live with her during 2000, and also that
she did not live at petitioner’s home in Dale City. Respondent
points to the school records of Joshua and Joseph and to Ms.
Jackson’s return for 2000 to support his allegation that Ms.
Jackson lived in the same house as petitioner during 2000;
however, we do not find these documents to be dispositive. We
find Ms. Jackson’s testimony to be credible and conclude that she
did not live in petitioner’s house during 2000.
We conclude that petitioner was the custodial parent and
Joshua and Joseph, therefore, are treated as receiving over half
of their support from petitioner. Id. Accordingly, petitioner
is entitled to the dependency exemption deductions for Joshua and
Joseph for the taxable year 2000.
2. Head-of-Household Filing Status
As relevant here, an individual shall be considered a head
of household if, and only if, he is not married at the close of
his taxable year, is not a surviving spouse, and maintains as his
home a household which constitutes for more than one-half of the
taxable year the principal place of abode, as a member of such
household, of an unmarried child of the taxpayer. Sec.
2(b)(1)(A)(i); sec. 1.2-2(b)(1), (b)(3), Income Tax Regs. A
taxpayer shall be considered as maintaining a household only if
he pays over half of the cost thereof for the taxable year. Sec.
2(b)(1); sec. 1.2-2(d), Income Tax Regs. The expenses of
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