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(B) such individual has not attained the age of
17 as of the close of the calendar year in which the
taxable year of the taxpayer begins, and
(C) such individual bears a relationship to the
taxpayer described in section 32(c)(3)(B).
Because petitioner is not allowed a deduction under section 151
with respect to any of the children, he does not have any
eligible or qualifying children. It therefore follows that he is
not entitled to a child tax credit under section 24(a), and we so
hold.
Decision will be entered
for respondent.
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Last modified: May 25, 2011