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Accordingly, petitioner is not entitled to a dependency deduction
for JJD for 2003.
II. Child Tax Credit
Section 24(a) provides that a taxpayer may claim a credit
for “each qualifying child”. A qualifying child is defined,
inter alia, as any individual if “the taxpayer is allowed a
deduction under section 151 with respect to such individual for
the taxable year”. Sec. 24(c)(1)(A).
We concluded that petitioner is not entitled to a dependency
deduction pursuant to section 151 for JJD for 2003.
Consequently, JJD is not a “qualifying child” pursuant to section
24(c). Accordingly, petitioner is not entitled to a child tax
credit under section 24(a) with respect to JJD for 2003.
III. Head of Household
Section 2(b) defines “head of household” as an individual
taxpayer who is: (1) Unmarried at the close of the taxable year;
and (2) maintains as his home a household which constitutes for
more than one-half of the taxable year the principal place of
abode of an unmarried son or daughter of the taxpayer. Sec.
2(b)(1)(A)(i).
Petitioner did not maintain a household that was the
principal place of abode for JJD for more than one-half of the
taxable year. Petitioner did not assert that any other
qualifying children lived with him for more than one-half of the
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