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(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 not
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