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continue a prior tax treatment that was wrong either on the law
or under the facts. See Thomas v. Commissioner, 92 T.C. 206,
226-227 (1989). “The mere fact that petitioner may have obtained
a windfall in prior years does not entitle * * * [him] to like
treatment for the taxable year here in issue.” Union Equity
Coop. Exch. v. Commissioner, 58 T.C. 397, 408 (1972), affd. 481
F.2d 812 (10th Cir. 1973); see also Schaeffer v. Commissioner,
T.C. Memo. 1994-227.
Child Tax Credit
A credit generally 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 we determined above that petitioner is not entitled
to the dependency exemption deduction for his children for the
1999 taxable year, he also is not entitled to the child tax
credit. Id.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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