Sean Michael Bears and Greta Bears - Page 9




                                        - 8 -                                         
         taxpayer may claim a deduction under section 151.  Sec.                      
         24(c)(1)(A).  Thus, a taxpayer is ineligible for the child tax               
         credit under section 24(a) unless the taxpayer is eligible for               
         the dependency exemption under section 151.  Having determined               
         that petitioners are not entitled to the dependency exemption                
         deduction, it follows that they are not entitled to the child tax            
         credit.  Accordingly, we sustain respondent’s disallowance of the            
         child tax credit.                                                            
              To reflect the foregoing,                                               


                                                       Decision will be              
                                                 entered for respondent.              

























Page:  Previous  1  2  3  4  5  6  7  8  9

Last modified: November 10, 2007