Conrad Fitzgerald Lewis - Page 13

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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.                    
               We have already held that petitioner is not entitled to a              
          dependency exemption deduction under section 151 for DD.                    

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