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must (a) be unmarried at the end of the taxable year, (b) not be
a surviving spouse, and (c) maintain as the taxpayer’s home a
household that constitutes for more than one-half of the taxable
year the principal place of abode of a son or daughter of the
taxpayer. Sec. 2(b)(1)(A)(i).
The parties have stipulated that Ms. Peterson had physical
custody of AH for more than one-half of the year. It follows,
therefore, that petitioner is not entitled to claim head-of-
household filing status. We sustain respondent’s determination
with respect to this issue.
Furthermore, we have considered all of the other arguments
made by petitioner, and, to the extent that we have not
specifically addressed them, we conclude they are without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011