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petitioner's return was processed, the Internal Revenue Service
assumed petitioner intended to claim a dependency exemption
deduction for Christopher and adjusted his return to allow
Christopher as a dependent. The resulting overpayment in tax was
refunded to petitioner. Petitioner also claimed head-of-
household filing status on his 1999 return.
In the notice of deficiency, respondent disallowed the two
dependency exemption deductions, disallowed the child care
credit, and determined petitioner's filing status as single. At
trial, respondent conceded petitioner's entitlement to the
dependency exemption deduction for Maggie. Petitioner conceded
he was not entitled to the dependency exemption deduction for
Christopher and the child care credit. Petitioner, however,
maintained his claim to head-of-household filing status on the
ground that, during 1999, he maintained a household that was the
principal place of abode for his daughter, Maggie.
Maggie was 22 years old during 1999. In the divorce decree,
many years earlier, she was placed in the custody of her mother.
Upon graduation from high school in 1995, Maggie enrolled as a
full-time student at the University of Richmond at Richmond,
Virginia. She graduated with a bachelor of science degree in
physical science in May 1999. She then entered Medical College
2(...continued)
the qualifying child.
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