Norma K. Litton - Page 12

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               B.  Child Tax Credit                                                   
               Section 24(a) provides that a taxpayer may claim a credit              
          for “each qualifying child”.  A qualifying child is defined,                
          inter alia, as any individual if “the taxpayer is allowed a                 
          deduction under section 151 with respect to such individual for             
          the taxable year”.  Sec. 24(c)(1)(A).  For the reasons stated               
          above, petitioner may claim dependency exemption deductions for             
          her son and daughter under section 151, and, therefore, she may             
          claim a child tax credit.  Respondent’s determination on this               
          issue is not sustained.                                                     
               C.  Conclusion                                                         
               Reviewed and adopted as the report of the Small Tax Case               
                    To reflect the foregoing,                                         

                                                  Decision will be entered            
                                             for petitioner.                          

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Last modified: May 25, 2011