Waylon D. Ary - Page 10




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               We have already held that petitioner is not entitled to                
          deductions under section 151 for dependency exemptions for his              
          two youngest sons.  Accordingly, neither of petitioner’s two                
          youngest sons is a “qualifying child” within the meaning of                 
          section 24(c).  It therefore follows that petitioner is not                 
          entitled to a child tax credit under section 24(a) in respect of            
          either such son.                                                            
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To give effect to our disposition of the disputed issues,              


                                                  Decision will be entered            
                                             for respondent.                          

























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