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right “to establish the legal residence of the child”.
Accordingly, Chinedu is not a “qualifying child” of petitioner.
An individual who does not have a “qualifying child” may
also be an “eligible individual” and thereby qualify for an
earned income credit. Sec. 32(c)(1)(A)(ii). However, to qualify
for 1999, the individual’s earned income and modified adjusted
gross income must both be less than $10,200; for 2000, less than
$10,380.
In view of our disposition of the Schedule C issues for 1999
and 2000, it would appear virtually certain that petitioner’s
earned income and modified adjusted gross income for each of
those years exceed the maximum amount allowable to claim an
earned income credit without regard to a “qualifying child”.
However, the parties should confirm this matter as part of their
computation for entry of decision under Rule 155.
E. Issue 4. Proceeds From the Sale of Stock
In the notice of deficiency, respondent determined that
petitioner received proceeds of $42 from the sale of stock in
2000.
Petitioner did not address this issue at trial; accordingly,
we consider it to have been abandoned by him. See, e.g., Watson
v. Commissioner, T.C. Memo. 2001-213. Respondent’s determination
is therefore sustained.
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