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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.
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Last modified: November 10, 2007