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disallowed the head-of-household filing status, child tax credit,
and dependency exemption deductions.1
Discussion
As the return for 1999 was filed after July 22, 1998,
section 7491(a) is applicable. Petitioner did not assert or
present evidence or argument that he satisfied the requirements
of section 7491(a). We conclude that resolution of the issues in
the present case does not depend upon who has the burden of
proof.
1. Dependency Exemption Deductions
A taxpayer may be entitled to claim as a deduction an
exemption amount for each of his or her dependents. Sec. 151(c).
An individual must meet the following five tests in order to
qualify as a dependent of the taxpayer: (1) Support test, (2)
relationship or household test, (3) citizenship or residency
test, (4) gross income test, and (5) joint return test. Secs.
151 and 152. If the individual fails any of these tests, he or
she does not qualify as a dependent.
As to the support test, a taxpayer generally must provide
more than half of a claimed dependent’s support for the calendar
year in which the taxable year of the taxpayer begins. Sec.
152(a). In the case of a child of divorced parents, if the child
1 Respondent determined that petitioner was entitled to a
filing status of single for the 1999 taxable year.
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