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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
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011