Ishmael Tarikh - Page 4

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          the 5 months the children lived with their mother during 2003,              
          petitioner paid $300 to her for support of the children.                    
          Petitioner provided no other support to the children, nor did               
          their mother provide any support to petitioner during the time              
          the children were with him.                                                 
               For the year at issue, 2003, petitioner and the children’s             
          mother both claimed the children as dependents on their                     
          respective Federal income tax returns.  Petitioner filed his 2003           
          return as a head-of-household under section 2(b)(1) and claimed             
          the dependency exemption deductions for the three children, the             
          earned income credit under section 32(a), and the child tax                 
          credit and the additional child tax credit under section 24.  In            
          the notice of deficiency, respondent disallowed the dependency              
          exemption deductions, petitioner’s head-of-household filing                 
          status, the earned income credit, the child care credit, and the            
          additional child care credit.                                               
               Deductions are a matter of legislative grace, and taxpayers            
          must maintain adequate records to substantiate the amounts of any           
          deductions or credits claimed.  Sec. 6001; INDOPCO, Inc. v.                 
          Commissioner, 503 U.S. 79, 84 (1992); sec. 1.6001-1(a), Income              
          Tax Regs.  Taxpayers generally bear the burden of proving that              











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