Bryant M. Hartfield - Page 6

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                         SEC. 152(a). General Definition.--For                        
               purposes of this subtitle, the term “dependent”                        
                    means any of the following individuals over half                  
                    of whose support, for the calendar year in which                  
                    the taxable year of the taxpayer begins, was                      
                    received from the taxpayer (or is treated under                   
                    subsection (c) or (e) as received from the                        
                         *    *    *    *    *    *    *                              
                         (9) An individual * * * who, for the                         
                    taxable year of the taxpayer, has as his                          
                    principal place of abode the home of the                          
                    taxpayer and is a member of the taxpayer’s                        
          Consequently, an individual may qualify as a “dependent” pursuant           
          to section 152(a)(9) without being related to the taxpayer.  Sec.           
          1.152-1(b), Income Tax Regs.                                                
               The record demonstrates that S.L.B.’s principal place of               
          abode during 2003 was petitioner’s residence and that she was a             
          member of petitioner’s household.  Moreover, petitioner has                 
          demonstrated that he paid the following amounts in support of               
          S.L.B. in 2003:                                                             
               Rent and utilities1                     $8,400                         
               Clothing                                1,100                          
               Food                                    720                            
               Personal hygiene                        360                            
               Transportation                          600                            
               School supplies                         100                            
               Allowance                               600                            
               1The $8,400 cost of rent and utilities is not                          
               apportioned between petitioner and S.L.B.                              
          We are satisfied that the aforementioned expenses represent the             
          total expenditures in support of S.L.B. during 2003.  For the               

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