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child” is defined in section 24(c). As relevant here, a
“qualifying child” means an individual with respect to whom the
taxpayer is allowed a deduction under section 151. Sec.
24(c)(1)(A).
We have already held that petitioners are not entitled to
the dependency exemption deduction under section 151 for BB.
Accordingly, BB is not considered a “qualifying child” within the
meaning of section 24(c). It follows, therefore, that
petitioners are not entitled to a child tax credit under section
24(a) with respect to BB.
In view of the foregoing, we sustain respondent’s
determination on this issue.
Furthermore, we have considered all of the other arguments
made by petitioners, 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
under Rule 155.
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Last modified: May 25, 2011