Heather Lee Comeau Sliwinski - Page 7

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          their support in 2000.  Sec. 152(a); see Lilley v. Commissioner,            
          T.C. Memo. 1989-602 (taxpayer is entitled to dependency exemption           
          based upon his credible testimony that he supplied over half of             
          the support for his daughter).  Further, we hold that petitioner            
          is entitled to a deduction for the exemption amount for Rebekah             
          and Michael because Rebekah and Michael are children of                     
          petitioner who have not attained the age limits provided for in             
          section 151(c)(1)(B).                                                       
          Head-of-Household Filing Status                                             
               In order to qualify for head-of-household filing status,               
          petitioner must satisfy the requirements of section 2(b).                   
          Pursuant to section 2(b), and as relevant therein, an individual            
          qualifies as a head of household if the individual is not married           
          or a surviving spouse at the close of the taxable year and                  
          maintains as his home a household that constitutes for more than            
          one-half of the taxable year the principal place of abode of a              
          son or daughter.  Sec. 2(b)(1)(A)(i).  Further, a taxpayer                  
          “maintains a household” if over half of the cost of maintaining             
          the household is furnished by the taxpayer.  Sec. 2(b)(1).                  
               We conclude that petitioner qualifies for head-of-household            
          filing status because she is not married or a surviving spouse,             
          her home was a household that constituted for more than one-half            
          of 2000 the principal place of abode for her son and daughter,              
          Michael and Rebekah, respectively, and petitioner credibly                  






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