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As previously indicated, petitioner offered little evidence
as to the total sources of support or his share of support for FA
and AA. Both petitioner and Ms. Briscoe helped pay for food and
utilities when they lived with petitioner’s mother, but neither
paid rent. While petitioner may have paid for room and board, we
have little information as to the total expenditures to support
the children during the period January to August 2005. After
petitioner moved with Ms. Briscoe and the children in August of
2005, petitioner paid one-half the rent for a period of time. At
some point during or after September 2005, petitioner paid the
entire rent. There is still insufficient evidence in this record
to establish the total cost of the children’s support during this
period, and thus petitioner failed to establish that he provided
more than half of the children’s support for 2005. Petitioner
has failed to prove that either FA or AA is a qualifying
relative.
Neither FA nor AA may be considered a qualifying child or a
qualifying relative; therefore, neither child may be considered
petitioner’s dependent. Petitioner is not entitled to a
dependency exemption deduction for FA or AA. Respondent’s
determination on this issue is sustained.
B. Child Tax Credits
Section 24(a) provides for a “credit against the tax * * *
for the taxable year with respect to each qualifying child of the
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