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equipment of $2,148.69, and unnamed other expenses of $6,241.45,
resulting in a net loss of $29,988.10.1
Discussion
Because petitioner failed to meet the requirements of
section 7491(a), the burden of proof with respect to factual
issues relevant to the deficiency does not shift to respondent.
As to the accuracy-related penalty, respondent has the burden of
production; the burden of persuasion remains with petitioner.
See sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446-447
(2001).
Dependency Exemption and Head of Household Filing Status
A dependency exemption deduction is allowed under section
151(a) for a parent of a taxpayer only if, among other
requirements, the taxpayer provides over half of the parent's
support for the year. See secs. 151(c) and 152(a)(4). A
taxpayer is considered a head of household with respect to a
parent only if, among other requirements, the taxpayer maintains
a household which constitutes the principal place of abode of
that parent, and the taxpayer is entitled to a dependency
exemption deduction for the parent for that taxable year. See
sec. 2(b)(1)(B). Although the taxpayer is not required to reside
with his parents for purposes of section 2(b), he must maintain
the household, which means that he must pay more than one-half
1The actual sum of the claimed items is $29,088.10.
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