Kevin Orlando McClain - Page 10

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               In the absence of other nonrefundable personal credits, a              
          taxpayer is allowed to claim a child tax credit in an amount that           
          is the lesser of the full child tax credit or the taxpayer’s                
          Federal income tax liability for the taxable year.  See sec.                
          26(a).  If the child tax credit exceeds the taxpayer’s Federal              
          income tax liability for the taxable year, a portion of the child           
          tax credit may be refundable as an “additional child tax credit”            
          under section 24(d)(1).  The refundable and nonrefundable                   
          portions of the child tax credit cannot exceed the total                    
          allowable amount of the credit.                                             
               Petitioner is not entitled to claim an additional child tax            
          credit because he did not qualify for a child tax credit.                   
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          

















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