Menace St. Hilaire - Page 8

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                         (2) such individual furnishes over one-half of the           
                    cost of maintaining such household during the taxable             
                    year, and                                                         
                         (3) during the last 6 months of the taxable year,            
                    such individual’s spouse is not a member of such                  
               such individual shall not be considered as married.                    
          These requirements are stated in the conjunctive, and the                   
          requirements of each paragraph must be satisfied.  We are willing           
          to assume, but do not decide, that petitioner satisfies the                 
          requirements of paragraphs (1) and (2).  We find, however, that             
          petitioner’s wife was a member of his household.2  Regardless of            
          what the sleeping arrangements may have been and where the                  
          household was, petitioner’s wife, Camelite, was very much a part            
          of his household.  By his own testimony, petitioner paid                    
          virtually all of the expenses for his family.  Camelite prepared            
          meals for the family, and, it appears to us, shared with                    
          petitioner the raising of all three children.  We conclude that             
          she and petitioner shared the same household.                               
               We have seen an increasing number of cases where there                 
          have been alleged convoluted living arrangements that have no               
          discernable substance except for attempts to take advantage of              
          tax deductions and credits.  Often this results from advice given           
          by tax return preparers who know better.  This is a dangerous               

          2  Sec. 7491 dealing with the burden of proof has no application            
          to this case because petitioner has not satisfied the                       
          requirements of sec. 7491(a).                                               

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