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beyond the plain language of the statute. Absent absurd,
unreasonable, or futile results, there is "no more persuasive
evidence of the purpose of a statute than the words by which the
legislature undertook to give expression to its wishes." United
States v. American Trucking Associations, 310 U.S. 534, 543
(1940).
Section 32(c)(1)(A) defines an eligible individual as an
individual who has a qualifying child for the taxable year. A
qualifying child is an individual who satisfies a relationship
test, an abode test, an age test, and for whom the taxpayer
satisfies an identification requirement. Sec. 32(c)(3)(A)(i)-
(iv). These requirements are conjunctive.
For the year in issue, Treymaine met the requirements of
section 32(c)(3)(A)(i), (ii), (iii), and (iv) with respect to
petitioner. With respect to his grandmother, Treymaine only met
the requirements of section 32(c)(3)(A)(i), (ii), and (iii).
What is significant here is that the grandmother did not identify
Treymaine as her qualifying child on her 1994 Federal income tax
return and thus failed to satisfy the requirement of section
32(c)(3)(A)(iv). Accordingly, Treymaine is not a qualifying
child with respect to his grandmother.
Because petitioner and the grandmother are not eligible
individuals with respect to the same qualifying child, section
32(c)(1)(C) does not preclude petitioner from entitlement to an
earned income credit for 1994. We cannot say that this
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