Ishmael Tarikh - Page 9

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               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 an individual with respect to whom the               
          taxpayer is allowed a deduction under section 151.  Sec.                    
          24(c)(1)(A).  Since petitioner is entitled to the dependency                
          exemption deductions under section 151, it follows he is entitled           
          to the child tax credit.                                                    
               The child tax credit is a nonrefundable personal credit that           
          was added to the Internal Revenue Code by the Taxpayer Relief Act           
          of 1997, Pub. L. 105-34, sec. 101(a), 111 Stat. 796, with a                 
          provision for a refundable credit, the additional child tax                 
          credit, for families with three or more children.  For taxable              
          years beginning after December 31, 2000, the additional child tax           
          credit provision was amended to remove the restriction that only            
          families with three or more children are entitled to claim the              
          credit.  Sec. 24(d)(1); Economic Growth and Tax Relief                      
          Reconciliation Act of 2001, Pub. L. 107-16, sec. 201(c)(1), 115             
          Stat. 46.                                                                   
               In the absence of other nonrefundable personal credits, a              
          taxpayer is allowed to claim a child tax credit in an amount that           
          is the lesser of the full child tax credit or the taxpayer’s                
          Federal income tax liability for the taxable year.  Sec. 26(a).             
          If the child tax credit exceeds the taxpayer’s Federal income tax           






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