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such written declaration. Further, the record does not indicate
that petitioner obtained a Form 8332 from Ms. Flanigan. At
trial, petitioner testified, with respect to Form 8332, that he
never signed or obtained such a form. Because petitioner, the
noncustodial parent, did not meet the requirements of the
Internal Revenue Code, he cannot fall within the exception
provided in section 152(e)(2). Since petitioner fails to meet
the requirements of the support test, the Court need not address
the other factors. Accordingly, the Court holds that petitioner
is not entitled to dependency exemption deductions for his two
children for 2003.
III. Child Tax Credit
For 2003, petitioner claimed a child tax credit with respect
to his two children in the amount of $1,000. Respondent asserts
that petitioner is not entitled to the child tax credit because
all of the unallocated family support payments that petitioner
made are alimony and not child support. Petitioner argues that
the unallocated family support payments, as well as the expenses
for medical and dental insurance for the two children, entitle
him to the child tax credit. We disagree.
Section 24(a) authorizes a child tax credit with respect to
each qualifying child of the taxpayer. The term “qualifying
child” is defined in section 24(c). A “qualifying child” means
an individual with respect to whom the taxpayer is allowed a
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