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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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