Rodger L. Smith - Page 9

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          financial contributor to the household.7  The relationship test             
          found in section 32(c)(3)(B) refers to lineal descendants of the            
          taxpayer, stepchildren, or foster children of the taxpayer.  It             
          does not mention siblings, or nephews.  This language shows that            
          Congress intended the earned income credit to be offered only to            
          parents actually caring for children.  We conclude that Sonya and           
          Pierre Tolbert do not fall within the definition of eligible                
          foster children for purposes of section 32.                                 
                                                  Decision will be entered            
                                             for respondent.                          

               7Petitioner testified that on the eve of trial he learned              
          that Pierre was required to see the doctor every 6 months.                  
          Although not conclusive, we believe that this testimony does not            
          support a finding that petitioner cared for Pierre as he would              
          his own child.                                                              

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