William A. Carcieri, Jr. - Page 9




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          head of household filing status.  Petitioner might have                     
          corroborated his testimony, but he failed to do so.                         
               The evidence supplied by petitioner fails to establish that            
          he provided the principal place of abode for Amanda for more than           
          one-half of the year in issue.  Moreover, petitioner offered no             
          evidence to show that he paid more than one-half the cost of                
          maintaining a household.  See sec. 2(b)(1).  We thus hold that              
          petitioner is not entitled to head of household filing status.              
          3.   Child Tax Credit                                                       
               Respondent determined that petitioner was unable to claim              
          the child tax credit on his 1998 return because he was unable to            
          substantiate that Amanda was a “qualifying child” as defined in             
          section 151.                                                                
               In the taxable year 1998, for the first time, taxpayers with           
          one or more qualifying children were able to claim a tax credit             
          of $400 for each qualifying child.  Sec. 24(a).  Section 24(c)(1)           
          defines a “qualifying child” as any individual if:                          
               (A) the taxpayer is allowed a deduction under section                  
               151 with respect to such individual for the taxable year,              
               (B) such individual has not attained the age of 17 as                  
               of the close of the calendar year in which the taxable                 
               year of the taxpayer begins, and                                       
               (C) such individual bears a relationship to the                        
               taxpayer described in section 32(c)(3)(B). [Emphasis                   
               added.]                                                                

          The plain language of section 24 establishes a three-pronged test           
          to determine whether a taxpayer has a qualifying child.  In                 
          effect, if one of the qualifications is not met, the claimed                






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