Daniel J. Onorati - Page 8

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          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 a dependency               
          exemption deduction for ZJ, JO, or AR.  Thus, petitioner fails              
          the first prong of the test of section 24.  The Court sustains              
          respondent’s determination regarding the child tax credits under            
          section 24.                                                                 
               Reviewed and adopted as the report of the Small Tax Case               
                                             Decision will be entered                 
                                        for respondent.                               

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