Matthew D. Gilmore - Page 9

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               As stated supra, the Court has sustained respondent’s                  
          determination that petitioner is not entitled to dependency                 
          exemption deductions for the children.  Thus, petitioner fails              
          the first prong of the test of section 24.  The Court sustains              
          respondent’s determination regarding the child tax credits under            
          section 24.                                                                 
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                             Decision will be entered                 
                                        under Rule 155.                              





























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