Darren M. Parker - Page 7

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          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).                                                                   
               Since petitioner is not allowed a deduction with respect to            
          DP and EW as dependents under section 151, they are not                     
          qualifying children.  In the absence of a qualifying child in               
          2003, petitioner is not entitled to claim 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              
          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).                                                                      






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