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Section 152(a) defines a dependent, inter alia, as a
daughter of the taxpayer “over half of whose support, for the
calendar year * * * was received from the taxpayer”. Since
petitioner did not contribute over half of his daughter’s
support, she is not a dependent and petitioner is not entitled to
claim a dependency exemption deduction for his daughter under
section 151(c).
Nonetheless, under section 1(b), a head of household is
entitled to a more favorable filing status than a single
individual. A head of household is defined, inter alia, as an
individual who is not married and maintains a household “which
constitutes for more than one-half of such taxable year the
principal place of abode” of an unmarried daughter. Sec.
2(b)(1)(A)(i). Petitioner satisfies these requirements and is
entitled to head of household filing status.
After the stipulation was filed and this case was tried,
petitioner moved to reopen the record. Respondent objected as to
some of the documents that petitioner lodged with the motion. To
the extent that we found the documents relevant and trustworthy,
we have incorporated them in this opinion. In all other
respects, petitioner’s motion is denied.
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Last modified: May 25, 2011