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taxable year”. Sec. 32(c)(3)(A)(ii) and (B)(i)(I). “Principal
place of abode” is not defined in the provisions relating to the
earned income credit. However, the provisions dealing with head-
of-household filing status are analogous. Sec. 2(b)(1); H. Conf.
Rept. 101-964, at 1037 (1990), 1991-2 C.B. 560, 564; sec. 1.2-
2(b) and (c), Income Tax Regs.
We have already concluded that petitioner did not maintain a
principal place of abode for RW as it relates to her status of
head of household. We come to the same conclusion here.
Petitioner did not provide a principal place of abode for RW for
more than half of the 2002 taxable year. Respondent is sustained
on this issue.
Petitioner may, however, still qualify for the earned income
credit. An individual who does not have a qualifying child may
be eligible under section 32(a) for an earned income credit,
subject to, among other things, phaseout limitations.
Merriweather v. Commissioner, T.C. Memo. 2002-226; Briggsdaniels
v. Commissioner, T.C. Memo. 2000-105, affd. 2 Fed. Appx. 848 (9th
Cir. 2001). An individual who does not have a qualifying child
is eligible for an earned income credit if: (1) The individual’s
principal place of abode is in the United States; (2) the
individual, or his or her spouse, has attained the age of 25 but
not the age of 65 at the close of the taxable year; and (3) the
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