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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
dependency exemption deductions under section 151 for KO and NW.
Accordingly, KO and NW are not considered “qualifying children”
within the meaning of section 24(c). It follows, therefore, that
petitioner is not entitled to a child tax credit under section
24(a) with respect to KO and NW.
In view of the foregoing, we sustain respondent’s
determination on this issue.
Furthermore, we have considered all of the other arguments
made by petitioner, 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
for respondent.
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Last modified: May 25, 2011