Manuella Cantrell - Page 8

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          cost of maintaining the household during the taxable year is                
          furnished by such taxpayer.  Sec. 2(b)(1).  “The cost of                    
          maintaining a household shall be the expenses incurred for the              
          mutual benefit of the occupants thereof by reason of its                    
          operation as the principal place of abode of such occupants for             
          such taxable year.”  Sec. 1.2-2(d), Income Tax Regs.  The                   
          expenses of maintaining a household include rent and food                   
          consumed on the premises, but does not include the cost of                  
          clothing, education, medical treatment, vacations, life                     
          insurance, transportation, or any amount which represents the               
          value of services rendered in the household by the taxpayer.  Id.           
               During the year in issue, petitioner was not married to Mr.            
          Cantrell and was not a surviving spouse.  Petitioner also                   
          maintained a household within the meaning of section 2(b)(1).               
          During 2001, there were four sources of funds to maintain                   
          petitioner’s household:  (1) Petitioner’s wages of $25,661 for              
          the year; (2) Section 8 housing subsidy of $825 per month or                
          $9,900 for the year; (3) child support from Mr. Cantrell of $370            
          every 2 weeks or $9,620 for the year; and (4) rent reduction of             
          $100 per month or $1,200 for the year because of her watching the           
          property on behalf of the landlord.                                         
               From a review of the entire record, we are satisfied that              
          petitioner furnished over half of the cost of maintaining a                 
          household in 2001.  Petitioner’s wages alone exceeded all other             






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