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Petitioner filed a Federal income tax return for taxable
year 1997 as a head of household. He claimed three dependency
exemption deductions, one for each of his children, and he
claimed an earned income credit with two qualifying children--
Lakeda and Twila. He reported the following income tax
liability:
Wage income $11,126
Standard deduction 6,050
Personal exemption deduction 2,650
Dependency exemption deductions 7,950
Taxable income -0-
Total tax -0-
Earned income credit 3,656
In the statutory notice of deficiency, respondent changed
petitioner’s filing status to single, disallowed the three
dependency exemption deductions, and disallowed the full amount
of the claimed earned income credit, because petitioner had not
provided supporting information.
At trial, respondent’s sole argument was that petitioner is
not entitled to head of household filing status, the dependency
exemption deductions, and the earned income credit, because he
has not provided documentary evidence proving he has legal
custody of the children.
Among other requirements, a taxpayer generally is entitled
to a dependency exemption deduction for a child if the taxpayer
provides over half of the child’s support during the taxable
year. Secs. 151(a), (c), and 152(a). The child’s gross income
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