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section 152(e)(1) does apply. Accordingly, petitioners are not
entitled to dependency exemption deductions for RW and MW for
2001. See sec. 152(e)(1); Miller v. Commissioner, supra.
Respondent’s determination on this issue is sustained.
B. 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 petitioners are not entitled to
dependency exemption deductions under section 151 for RW and MW.
Accordingly, RW and MW are not considered “qualifying children”
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 RW and MW.
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.
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