Christopher Christie - Page 7

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          incarceration and began residing with his mother and aunt,                  
          Shirley Johnson and her child moved in with them.  Petitioner               
          acknowledged that Shirley Johnson held part-time jobs during that           
          period, although no evidence was presented as to the amount of              
          her earnings or other sources of support she may have had, nor              
          was any evidence presented to show what amounts petitioner                  
          provided to his daughter for her support.  The home was not owned           
          by petitioner, although he claimed at trial that he paid the                
          utilities and the groceries for all the occupants of the home.              
          Petitioner, however, maintained no records to document the                  
          amounts that were expended by him and, in particular, the amounts           
          spent for his daughter.  His mother and aunt were both receiving            
          retirement benefits and presumably shared in some of these                  
          expenses.  On this record, the Court concludes that petitioner              
          failed to establish that he provided more than half of La Toya              
          Johnson's support during 2000.  Respondent is sustained on this             
          issue.                                                                      
               The second issue is whether petitioner is entitled to head-            
          of-household filing status for the year at issue.  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              







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