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The term “qualifying child” is defined in section 24(c). As
relevant herein, a “qualifying child” means an individual with
respect to whom the taxpayer is allowed a deduction under section
151. Sec. 24(c)(1)(A).
We have already held that petitioner is not entitled to a
deduction under section 151 for a dependency exemption for any of
his children. Accordingly, none of petitioner’s children is a
“qualifying child” within the meaning of section 24(c). It
follows, therefore, that petitioner is not entitled to a child
tax credit under section 24(a) and an additional child tax credit
under section 24(d) in respect of his children.
In view of the foregoing, we sustain respondent’s
determination on this issue.
C. Filing Status
As relevant herein, an individual qualifies as a head of
household if the individual is not married at the close of the
taxable year and maintains as his or her home a household that
constitutes for more than one-half of the taxable year, the
principal place of abode of a son or daughter of the taxpayer.
See sec. 2(b)(1)(A)(i).
Although petitioner may have maintained a residence for his
children, petitioner had physical custody of his children for
less than half of the year, and his residence was not the
principal place of abode of any of his children for more than
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