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support during the years in issue. Therefore, we hold that
petitioner is not entitled to section 151 dependency exemption
deductions for the 1995 and 1996 tax years.3 Respondent is
sustained on this issue.
Head of Household Status
According to the relevant part of section 2(b), an
individual shall be considered a head of household if such
individual (1) is not married at the close of the taxable year
and (2) maintains as his home a household which constitutes for
more than one-half of the taxable year the principal place of
abode of a stepdaughter or of any other person who is a dependent
of the taxpayer, if the taxpayer is entitled to a deduction for
the taxable year for such person under section 151.
Because the parties stipulated that the children did not
reside with petitioner during any part of the years in issue, and
because we held above that petitioner is not entitled to a
deduction for the children under the provisions of sections 151
and 152, petitioner is not entitled to head of household status.
Therefore, respondent is sustained on this issue.
3 It is therefore unnecessary to address whether Varela
Kenneth is petitioner’s stepdaughter.
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