Untayia L. Chizer - Page 8

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          determined that petitioner is not entitled to an additional child           
          tax credit for 2003.                                                        
               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).  A “qualifying child” means             
          an individual with respect to whom the taxpayer is allowed a                
          deduction under section 151, who has not attained the age of 17             
          as of the close of the taxable year and who bears a relationship            
          to the taxpayer as prescribed by section 32(c)(3)(B).  Sec.                 
          24(c)(1).  Because petitioner has not shown that she is entitled            
          to a deduction under section 151 for a “qualifying child”, she is           
          not entitled to a child tax credit.                                         
               The child tax credit is a nonrefundable personal credit that           
          was added to the Internal Revenue Code by the Taxpayer Relief Act           
          of 1997, Pub. L. 105-34, sec. 101(a), 111 Stat. 796, with a                 
          provision for a refundable credit, the “additional child tax                
          credit”, for families with three or more children.  For taxable             
          years beginning after December 31, 2000, the additional child tax           
          credit provision was amended to remove the restriction that only            
          families with three or more children are entitled to claim the              
          credit.  See sec. 24(d)(1); Economic Growth and Tax Relief                  
          Reconciliation Act of 2001, Pub. L. 107-16, sec. 201(c)(1), 115             
          Stat. 46.                                                                   
               In the absence of other nonrefundable personal credits, a              






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