Clyde Everton Allsopp - Page 10

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          II.  Child Tax Credit                                                       
               In addition to the exemption under section 151(a), a child             
          tax credit generally is allowed to a taxpayer for each qualifying           
          child of the taxpayer.  Sec. 24(a).  Among other requirements, a            
          qualifying child is an individual for whom the taxpayer is                  
          allowed a dependency exemption under section 151.  Sec.                     
          24(c)(1)(A).  For the reasons stated above, petitioner may not              
          claim a dependency exemption for Everton or Aldwyn under section            
          151, and, therefore, he may not claim a child tax credit with               
          respect to either of them.  Respondent’s determination on this              
          issue is sustained.                                                         
          III.  Conclusion                                                            
               We have considered all of the other arguments made by the              
          parties, and, to the extent that we have not specifically                   
          addressed them, we conclude they are without merit.                         
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                             Decision will be entered                 
                                        for respondent.                               














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