Andre L. Wilson - Page 12

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          the notice of deficiency, respondent disallowed the child tax               
               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.                    
               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               

                                             Decision will be entered                 
                                        for respondent.                               

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