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in the home of their foster parents. Accordingly, we conclude
that petitioner is not entitled to head of household filing
status.
II. Dependency Exemptions
A taxpayer may claim exemptions for individuals who qualify
as the taxpayer’s dependents. Sec. 151(a), (c)(1). Section
152(a)(1) includes a taxpayer’s children as dependents if the
taxpayer provided over half of their support during the calender
year.
Petitioner testified at trial that she occasionally bought
food, clothes, school supplies, and toys for Frankie and Avery.
Petitioner did not introduce any documentary evidence in support
of her testimony. Even assuming that petitioner’s
unsubstantiated testimony correctly accounts for her
contributions toward Frankie and Avery’s support, petitioner
clearly did not provide over half of their support as required by
section 152(a). We therefore sustain respondent’s determination
that petitioner is not entitled to claim dependency exemptions
for her two sons.
III. Earned Income Credit
Section 32(a)(1) provides an income tax credit, subject to
limitation by section 32(a)(2), for taxpayers who satisfy certain
eligibility requirements. Pursuant to section 32(c)(1)(A)(i), a
taxpayer is eligible for the earned income credit if the taxpayer
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Last modified: May 25, 2011