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2001, and 2002. In fact, petitioner testified that the
Department of Social Services provided funding that completely
paid for all of DD’s support for the taxable years at issue in
the present case.
Upon the basis of the record before us, we find that
petitioner has not established that his home during taxable year
2000, 2001, and 2002 was the principal place of abode of DD.
Further, we find that petitioner has failed to establish the
total support costs for the claimed individual, DD, and that he
provided at least half of that amount. Respondent’s
determination on this issue is sustained.
2. Child Tax Credit
As previously stated, petitioner claimed a child tax credit
for taxable years 2000, 2001, and 2002 with DD 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 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 a
dependency exemption deduction under section 151 for DD.
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