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issues in the case at bar. Therefore, petitioner bears the
burden of showing that he is entitled to claim a dependency
exemption deduction for JTMZ; that he is entitled to head-of-
household filing status; and that he is entitled to an earned
income credit for taxable year 2002.
Moreover, deductions are a matter of legislative grace and
are allowed only as specifically provided by statute. INDOPCO,
Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice
Co. v. Helvering, 292 U.S. 435, 440 (1934).
1. Deduction for Dependency Exemption
As previously stated, on his 2002 Federal income tax return,
petitioner claimed a dependency exemption deduction for JTMZ.
Respondent disallowed the deduction in the notice of deficiency.3
Section 151 allows deductions for personal exemptions.
Besides providing exemptions for the taxpayer and, in certain
circumstances, the taxpayer’s spouse, section 151 provides
exemptions for dependents of the taxpayer. See sec. 151(c).
Section 152(a) defines the term “dependent”, in pertinent part,
3The notice of deficiency did not question the paternity of
JTMZ. Instead, the Commissioner, in the notice of deficiency,
denied petitioner the dependency exemption deduction, head-of-
household filing status, and the earned income credit because
petitioner did not establish that his residence constituted the
principal place of abode for JTMZ for more than one-half of the
taxable year, nor did petitioner substantiate that he provided
more than one-half of JTMZ’s support for taxable year 2002.
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