- 10 - D. Child Tax Credit Petitioner claimed a child tax credit for the taxable year 2003 with SAB as the qualifying child. In 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 to these facts, 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 the dependency exemption deduction under section 151 for SAB. Accordingly, SAB is not considered a “qualifying child” within the meaning of section 24(c). It follows, therefore, that petitioner is not entitled to a child tax credit under section 24(a). In view of the foregoing, we sustain the respondent’s determination on this issue. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011