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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.
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