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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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