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as a member of such household, of any person who is a dependent
of the taxpayer, if the taxpayer is entitled to a deduction for
the taxable year for such person under section 151. Section 151
allows the taxpayer to claim an exemption deduction for a
dependent whose gross income for the calendar year in which the
taxable year of the taxpayer begins is less than the “exemption
amount”. Sec. 151(c)(1)(A) and (d)(1). Included among those
that qualify as dependents is a taxpayer’s brother, so long as
more than half of his support for the year at issue was received
from the taxpayer. See sec. 152(a)(3).
Petitioner, who during 2000 was married but separated from
her husband, testified that her brother, born in 1976, has been
living with her since his last year in high school. She stated
that since then she has been supporting her brother and has paid
all his expenses, including his education, food, clothing, and
rent. Petitioner testified that her brother worked in several
part-time jobs during 2000 but that she did not know how much he
had earned. Respondent introduced into evidence documents
showing that petitioner’s brother filed a Federal income tax
return for 2000 in which he reported gross income of $7,789.
We have already noted that the burden is on petitioner to
establish that she is entitled to head-of-household filing
status. Apart from petitioner’s testimony, however, she did not
offer any other credible evidence that would substantiate that
her home constituted the principal place of abode for her brother
during the year in question or that she provided more than half
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