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From his presentation at trial, we are satisfied that
petitioner understands that his entitlement to the child tax
credit claimed on his 1998 return depends upon his entitlement to
the dependency exemption deduction claimed for his son. For
1998, petitioner’s son is not petitioner’s qualifying child for
purposes of the child tax credit because petitioner is not
entitled to a dependency exemption deduction for his son for that
year. See sec. 24(a), (c). Respondent’s disallowance of the
child tax credit claimed on petitioner’s 1998 return is
sustained.
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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Last modified: May 25, 2011