Christopher Christie - Page 8

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          abode, as a member of such household, of an unmarried son or                
          daughter of the taxpayer.  See sec. 2(b)(1)(A)(i).                          
               The evidence fails to establish that petitioner maintained             
          as his home "a household" that constituted the principal place of           
          abode for La Toya Johnson.  Petitioner did not own the home where           
          he resided (for only half the year), and his claim to paying the            
          costs for utilities and food for maintenance of the household               
          does not satisfy the Court that petitioner "maintained" a                   
          household during the year at issue.  Respondent, therefore, is              
          sustained in the disallowance of petitioner's claimed head-of-              
          household filing status.                                                    
               The final issue is petitioner's claim to the earned income             
          credit.  Section 32(a) provides for an earned income credit in              
          the case of an eligible individual.  Section 32(c)(1)(A), in                
          pertinent part, defines an "eligible individual" as an individual           
          who has a qualifying child for the taxable year.  Sec.                      
          32(c)(1)(A)(i).  A qualifying child is one who satisfies a                  
          relationship test, a residency test, an age test, and an                    
          identification requirement.  See sec. 32(c)(3).  To satisfy the             
          age test, the qualifying child must not have attained the age of            
          19 as of the close of the calendar year in which the taxable year           
          of the taxpayer begins.  Sec. 32(c)(3)(C)(i).  Petitioner's                 
          daughter, La Toya Johnson, attained age 20 on October 4, 2000.              
          Therefore, petitioner's daughter does not satisfy the age test              





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