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pay her bills at least until March 2004 when petitioner moved
into the mobile home. Petitioner has failed to provide the Court
with any evidence establishing that he provided over half of TE’s
and TG’s support during the 2004 taxable year. Accordingly, the
Court is constrained to conclude that petitioner is not entitled
to dependency exemption deductions for TE and TG for 2004.
II. Head of Household Filing Status
Section 1(b) provides a special lower tax rate for an
individual filing his Federal tax return as a head of household.
Section 2(b) defines a “head of household” as an individual
taxpayer who is: (1) Unmarried at the close of the taxable year
and is not a surviving spouse, and (2) maintains as his home a
household which constitutes for more than one-half of the taxable
year the principal place of abode of a dependent of the taxpayer
with respect to whom the taxpayer is allowed a deduction under
section 151. Sec. 2(b)(1)(A)(i) and (ii). This Court has
already concluded that petitioner is not entitled to dependency
exemption deductions under section 151 for TE and TG.
Accordingly, petitioner is not entitled to head of household
filing status.
III. Child Tax Credits
Section 24(a) authorizes a child tax credit with respect to
each “qualifying child” of the taxpayer. As relevant to these
particular facts, a “qualifying child” means, among other things,
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Last modified: November 10, 2007