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child tax credit must be disallowed. The first element of the
three-pronged test requires that to qualify for the child tax
credit, a taxpayer must have been allowed a deduction for that
child under section 151. Sec. 24(c)(1)(A).
Respondent determined that petitioner was not entitled to a
section 151 dependency exemption deduction for Amanda in 1998.
We have previously held that respondent’s determination regarding
the section 151 deduction was valid. That holding is dispositive
of this issue, and, as a result, we sustain respondent’s
determination regarding the section 24 child tax credit and hold,
because of the plain language of the statute, that petitioner is
not eligible to claim the child tax credit.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011