April Lennett Webb-Reed - Page 8

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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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