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satisfies the requirement to substantiate items. Sec.
7491(a)(2)(A). Petitioner has not offered any evidence that she
satisfies any of the criteria of section 7491(a)(2)(A). The
burden of proof has not shifted to respondent; therefore, it
remains on petitioner.
1. Head of Household
Section 1(b) imposes a special tax rate on an individual
filing as a head of household. As relevant herein, section 2(b)
defines a “head of household” as an unmarried individual who
maintains as his or her home a household that for more than one-
half of the taxable year constitutes the principal place of abode
of an unmarried child of the individual. Sec. 2(b)(1)(A)(i).
Petitioner’s eligibility for head-of-household filing status
primarily depends on whether she maintained a home that for more
than one-half of the taxable year was the principal place of
abode of her daughter. A key factor in resolving this issue is
whether RW’s absence from petitioner’s home, while attending high
school in Indiana, can be considered a temporary absence.
In January 2000, petitioner moved from Indiana to San
Diego, California, so that she could attend law school. RW lived
with petitioner in Indiana before petitioner moved to San Diego.
Petitioner’s move to San Diego occurred in the middle of RW’s
eighth-grade school year. RW did not move to San Diego with
petitioner. Before fall 2000, petitioner assumed that RW would
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