- 6 - (3) the taxpayer contributed over 10 percent of such support; and (4) each person described in paragraph (2) (other than the taxpayer) who contributed over 10 percent of such support files a written declaration (in such manner and form as the Secretary may by regulations prescribe) that he will not claim such individual as a dependent for any taxable year beginning in such calendar year. Petitioner has failed to demonstrate that no one person contributed over half of the support for FM or MM in 2004. Furthermore, neither petitioner’s mother nor any other member of his family filed a written declaration allowing petitioner to claim FM or MM as a dependent. Accordingly, we conclude there was no multiple support agreement with respect to FM or MM. See sec. 152(c)(1), (4). Petitioner therefore is not entitled to the claimed deductions, and respondent’s determination is sustained. II. Child Tax Credits Section 24(a) provides for a “credit against the tax * * * for the taxable year with respect to each qualifying child of the taxpayer”. The term “qualifying child” means any individual if three requirements are met, one of which is that the taxpayer be allowed a deduction under section 151 with respect to such individual for the taxable year. Sec. 24(c)(1). Because we conclude that petitioner is not entitled to a dependency exemption deduction with respect to FM or MM, they are notPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011