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At trial, petitioner’s father, Jerry McClain (Mr. McClain),
offered testimony relating to the amount of support that
petitioner paid for DR and AM during 2004. Mr. McClain’s
testimony, however, is not persuasive because he has no personal
knowledge as to any of the matters to which he testified. Mr.
McClain’s testimony was based entirely on what petitioner told
him.
The Court concludes that petitioner has not offered
sufficient evidence to show that he provided more than half of
DR’s and AM’s support in 2004.
Head of Household
In the notice of deficiency, respondent determined
petitioner’s filing status to be single rather than head of
household.
Section 1(b) imposes a special tax rate on individuals
filing as “heads of households”. “Head of household” is defined
in section 2(b) to include an unmarried individual who maintained
as his home a household which constitutes for more than one-half
of the taxable year the principal place of abode for persons for
whom the taxpayer is entitled to claim dependency exemption
deductions under section 151. See sec. 2(b)(1)(A)(ii). A
taxpayer is considered to be maintaining a household only if over
half of the cost of maintaining the household during the taxable
year is furnished by the taxpayer. Sec. 2(b).
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Last modified: May 25, 2011