Huon Pen - Page 6

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          allowable to the taxpayer providing more than one-half of the               
          total support provided to the dependent during any given year.              
          Petitioner’s support did not reach that level.  Most of the                 
          support came from the other sources described.  However, there              
          was an avenue petitioner could have availed herself of that would           
          have allowed her to claim the dependency exemption deduction.               
          She could have obtained a multiple support agreement where all              
          providers of support to L.H. agreed to allow the dependency                 
          exemption deduction to one of their number.  Form 2120, Multiple            
          Support Agreement, is the proper medium by which this is                    
               Petitioner did not include such an agreement with her                  
          return; consequently, she is not entitled to the dependency                 
          exemption deduction.  Respondent, therefore, is sustained on this           
               The next issue is petitioner’s claim to head-of-household              
          filing status under section 2(b)(1).                                        

               3The Form 2120 is an acknowledgment by a group of                      
          contributors who have collectively provided over one-half of a              
          dependent’s support for a calendar year and who may annually                
          designate one of their number to claim the dependency exemption             
          deduction for the dependent.  The taxpayer who is designated as             
          entitled to claim the dependency exemption deduction must attach            
          a statement to his or her return identifying each member of the             
          supporting group and, in general, comply with sec. 1.152-3,                 
          Income Tax Regs.                                                            

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