Karen Ann Cicchini - Page 9




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         Child Support Record maintained by the Texas State court,                    
         indicate that Mr. Anker paid $74,893.46 for that period.6                    
         Accordingly, it cannot be said that “all child support herein                
         ordered to be paid by claimant [was] timely paid.”                           
              In view of the foregoing, we hold that petitioner is                    
         entitled to deductions for dependency exemptions for her two                 
         sons.  Sec. 152(e)(1).                                                       
              B.  Child Tax Credit                                                    
              Section 24(a) authorizes a $400 child tax credit with                   
         respect to each “qualifying child” of the taxpayer.  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 entitled to                     
         deductions under section 151 for dependency exemptions for her               
         two sons.  Accordingly, each of petitioner’s sons is a                       
         “qualifying child” within the meaning of section 24(c).                      
         Accordingly, and because respondent does not suggest that                    
         petitioner does not otherwise satisfy the requirements of                    
         applicable law, petitioner is entitled to a child tax credit                 
         under section 24(a) in respect of her sons.                                  



               6 This amount is net of dishonored checks.                             





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