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(ii) who has the same principal place of abode as
the taxpayer for more than one-half of such taxable
year, and
(iii) who meets the age requirements of
subparagraph (C).
As previously stated, petitioner has not established that
his residence was the principal place of abode for KH for more
than one-half of the taxable year 2002. We find that KH fails
the residency test of section 32(c)(3)(ii). Accordingly,
respondent’s determination on this issue is sustained.
4. Child Tax Credit
As previously stated, petitioner claimed a child tax credit
for taxable year 2002 with KH as the qualifying child. In the
notice of deficiency, respondent disallowed the child tax credit.
Section 24(a) authorizes a child tax credit with respect to
each “qualifying child” of the taxpayer. The term “qualifying
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 petitioner is not entitled to the
dependency exemption deduction under section 151 for KH.
Accordingly, KH is not considered a “qualifying child” within the
meaning of section 24(c). It follows, therefore, that petitioner
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