Dimitri L. Harris - Page 9




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          Additional Child Tax Credit                                                 
               The final issue is whether petitioner is entitled to claim             
          the additional child tax credit under section 24.                           
               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).  As relevant to this case, a            
          qualifying child means a qualifying child as defined in section             
          152(c) who has not reached the age of 17.  Sec. 24(c)(1).                   
               Earlier in this opinion, the Court held that the children              
          were not qualifying children of petitioner as defined in section            
          152(c).  Accordingly, petitioner is not entitled to the                     
          additional child tax credit under section 24(a).  Respondent is             
          sustained on this issue.                                                    
                                                  Decision will be entered            
                                             for respondent.                          





















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