Estella De La Garza v. Commissioner of Internal Revenue

Fifth Circuit

Estella De La Garza v. Commissioner of Internal Revenue

378 F.2d 32, 19 A.F.T.R.2d (RIA) 1553, 1967 U.S. App. LEXIS 6136

Court of Appeals for the Fifth Circuit·Decided June 2, 1967·No. 24220_1·Published·Cited by 15 cases

Opinion

PER CURIAM:

Petitioner seeks a review of a decision of the Tax Court 1 sustaining a deficiency in her federal income tax for the taxable year 1962. The Tax Court held that although a multiple support agreement was executed pursuant to Section 152 (c), Internal Revenue Code 1954, the petitioner is not entitled to a dependency exemption for her sister where the sister contributed $409.71 to a common family fund used for the support of all members of the household which was greater than one-half of the total expenditure of $678.80 from the common fund for the sister’s support.

The Tax Court properly interpreted the applicable provisions of the code and regulations and its decision is

Affirmed.

1

46 T.C. 446.

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PER CURIAM:

Petitioner seeks a review of a decision of the Tax Court 1 sustaining a deficiency in her federal income tax for the taxable year 1962. The Tax Court held that although a multiple support agreement was executed pursuant to Section 152 (c), Internal Revenue Code 1954, the petitioner is not entitled to a dependency exemption for her sister where the sister contributed $409.71 to a common family fund used for the support of all members of the household which was greater than one-half of the total expenditure of $678.80 from the common fund for the sister’s support.

The Tax Court properly interpreted the applicable provisions of the code and regulations and its decision is

Affirmed.

1

46 T.C. 446.

Estella De La Garza v. Commissioner of Internal Revenue, 378 F.2d 32, 19 A.F.T.R.2d (RIA) 1553, 1967 U.S. App. LEXIS 6136 (5th Cir. 1967).

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378 F.2d 32 (Estella De La Garza v. Commissioner of Internal Revenue) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Opinion

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