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The Court is not satisfied from the evidence that petitioner
provided more than half of the support for Christopher during the
year at issue. Petitioner presented no evidence to show the
total support that was provided to the child during 2000 and the
amount he provided to establish that such amount met the one-half
threshold required under section 152(a). Moreover, the evidence
does not satisfy the Court that Christopher was petitioner's son
or stepson. Although section 152(a)(9) allows a dependency
exemption for a person who is not a child or other allowed
relative of the taxpayer, that provision requires as a condition
for the dependency exemption that the claimed dependent, for the
entire taxable year, had as his principal place of abode the home
of the taxpayer and was a member of the taxpayer's household.
Petitioner's evidence does not satisfy the Court that Christopher
was a member of petitioner's household or had his principal place
of abode with petitioner for the year 2000. Likewise,
Christopher does not qualify as a foster son pursuant to section
152(b)(2). The Court, therefore, sustains respondent on the
dependency question.
Section 2(b) provides generally that an individual shall be
considered a head-of-household if, among other requisites not
pertinent here, such individual maintains as his home a household
that constitutes for more than one-half of such taxable year the
principal place of abode, as a member of such household, of an
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