Michael J. Gentner - Page 7




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               The second issue for decision is whether petitioner is                 
          entitled to four child tax credits for taxable year 1998.                   
               Subject to limitations and exceptions not applicable here, a           
          $400 credit is allowed to a taxpayer for each qualifying child of           
          the taxpayer.  Sec. 24(a).  Among other requirements, a                     
          qualifying child is one for whom the taxpayer is entitled to a              
          dependency exemption deduction under section 151.  Sec.                     
          24(c)(1)(A).  Because petitioner is not entitled to the                     
          dependency exemption deductions for his children, he also is not            
          entitled to the child tax credits for them.                                 
               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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