Menace St. Hilaire - Page 5

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          he provided more than half of the support for Mackcande.  It is             
          unclear whether respondent still contends that petitioner is not            
          entitled to the dependency exemption deduction; we are satisfied,           
          however, that petitioner provided more than half of the support             
          for Mackcande.  Accordingly, petitioner is entitled to a                    
          dependency exemption deduction for Mackcande.                               
               Section 24 provides a CTC for a qualifying child.  A                   
          qualifying child includes an individual, under the age of 17, for           
          whom the taxpayer is allowed to claim a deduction under section             
          151 and who bears a relationship to the taxpayer as described in            
          section 32(c)(3)(B).  Sec. 24(c)(1).  Petitioner claimed the CTC            
          for Mackcande as a qualifying child.  Respondent agrees that                
          Mackcande is a qualifying child if petitioner can claim a                   
          dependency exemption deduction for him under section 151.  As               
          discussed above, petitioner is entitled to claim Mackcande as a             
          dependent and, therefore, is also entitled to a CTC under section           
          Child Care Credit                                                           
               Section 21 provides for a credit for a percentage of the               
          expenses for the care of a child under age 13 paid by an                    
          individual to enable the individual to be gainfully employed.               
          Section 21(e)(2) provides that if an individual is married at the           
          end of the taxable year, the individual and his spouse must file            

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