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defines a “head of household” as an unmarried individual who
maintains as her home a household that for more than one-half of
the taxable year constitutes the principal place of abode of a
person who is a dependent of the taxpayer, if the taxpayer is
entitled to a deduction for the taxable year for that dependent
under section 151.
Respondent determined that petitioner is not entitled to
section 151 dependency exemption deductions for Eric and
Cassandra in 1999. The Court has sustained respondent’s
determination regarding the section 151 deductions. That holding
is dispositive of this issue, and, as a result, the Court
sustains respondent’s determination that petitioner is not
entitled to claim head of household filing status for 1999.
4. Child Tax Credit
For the taxable year 1999, taxpayers are allowed to claim a
tax credit of $500 for each qualifying child. Sec. 24(a). The
plain language of section 24 establishes a three-pronged test to
determine whether a taxpayer has a qualifying child. If one of
the qualifications is not met, the claimed child tax credit must
be disallowed. The first element of the three-pronged test
requires that a taxpayer must have been allowed a deduction for
that child under section 151. Sec. 24(c)(1)(A).
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
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Last modified: May 25, 2011