Darren M. Parker - Page 8

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               If the child tax credit exceeds the taxpayer’s Federal                 
          income tax liability for the taxable year, a portion of the child           
          tax credit may be refundable as an “additional child tax credit”            
          under section 24(d)(1).                                                     
               Petitioner is not entitled to claim an additional child tax            
          credit because he did not qualify for a child tax credit.                   
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          



























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