Elnora F. Hodnett - Page 6




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          taxpayer.  Sec. 24.  An individual is a qualifying child of the             
          taxpayer for purposes of the child tax credit if, in addition to            
          other requirements, the taxpayer is entitled to a dependency                
          exemption deduction for the individual.  Sec. 24(c).                        
               As discussed above, petitioner is not entitled to a                    
          dependency exemption deduction for either of her grandchildren              
          for 1998.  Consequently, for purposes of the child tax credit,              
          neither of petitioner’s grandchildren is her qualifying child for           
          that year, and she is not entitled to the child tax credits here            
          in dispute.  Respondent’s disallowance of those credits is                  
          sustained.                                                                  
               Petitioner claimed head of household filing status on her              
          1998 return.  A taxpayer qualifies as a head of household if, in            
          addition to other situations and among other requirements, during           
          the year the taxpayer furnishes over half of the cost of                    
          maintaining, as the taxpayer’s home, “a household which                     
          constitutes for more than one-half of such taxable year the                 
          principal place of abode, as a member of such household, of”,               
          among other individuals, a grandchild of the taxpayer.  Sec.                
          2(b)(1)(A)(i).                                                              
               The cost of maintaining the household of which petitioner              
          was a member during 1998 was furnished in part through the public           
          assistance benefits received by petitioner’s daughter, and in               
          part by petitioner.  The evidence in this case does not establish           






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