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

CourtCourt of Appeals for the Fifth Circuit

DecidedJune 2, 1967

Docket24220_1

StatusPublished

Cited by15 cases

This text of 378 F.2d 32 (Estella De La Garza v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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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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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.

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Bluebook (online)

378 F.2d 32, 19 A.F.T.R.2d (RIA) 1553, 1967 U.S. App. LEXIS 6136, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estella-de-la-garza-v-commissioner-of-internal-revenue-ca5-1967.

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