Elnora F. Hodnett - Page 3




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               Respondent determined a deficiency of $4,249 in petitioner’s           
          1998 Federal income tax.  The issues for decision are: (1)                  
          Whether petitioner qualifies as a head of household;                        
          (2) whether petitioner is entitled to dependency exemption                  
          deductions for two of her grandchildren; and (3) whether                    
          petitioner is entitled to child tax credits for two of her                  
          grandchildren.                                                              
          Background                                                                  
               Some of the facts have been stipulated and are so found.               
          At the time the petition was filed, petitioner resided in                   
          Roanoke, Virginia.                                                          
               Petitioner is the mother of Karen Renee Hodnett                        
          (petitioner’s daughter), and grandmother of Dajaneke Hodnett and            
          Da’Shawn Hodnett (petitioner’s grandchildren), who are children             
          of petitioner’s daughter.  During the year in issue they all                
          lived together in an apartment leased to petitioner’s daughter.             
          Petitioner’s daughter or petitioner contributed approximately               
          $89 per month toward the rent of the apartment.  The balance of             
          the rent, which cannot be determined from the record, was                   
          subsidized under a Federal or State public assistance program.              
               Petitioner’s daughter was unemployed throughout 1998.                  
          During that year, petitioner contributed unspecified amounts,               
          presumably for food, clothing, etc., toward the support of her              
          daughter and grandchildren.  The fathers of petitioner’s                    






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