Sowder v. Commissioner

1971 T.C. Memo. 104, 30 T.C.M. 451, 1971 Tax Ct. Memo LEXIS 222
CourtUnited States Tax Court
DecidedMay 17, 1971
DocketDocket No. 2080-70.
StatusUnpublished

This text of 1971 T.C. Memo. 104 (Sowder v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sowder v. Commissioner, 1971 T.C. Memo. 104, 30 T.C.M. 451, 1971 Tax Ct. Memo LEXIS 222 (tax 1971).

Opinion

Fred A. Sowder v. Commissioner.
Sowder v. Commissioner
Docket No. 2080-70.
United States Tax Court
T.C. Memo 1971-104; 1971 Tax Ct. Memo LEXIS 222; 30 T.C.M. (CCH) 451; T.C.M. (RIA) 71104;
May 17, 1971, Filed.

*222 Noncustodial parent failed to prove that he is entitled to dependency exemption for child in custody of divorced wife under either section 152(a) or section 152(e), I.R.C. 1954.

Fred A. Sowder, pro se, 956 Ludlow Ave., Cincinnati, Ohio. Juandell D. Glass, for the respondent.

DRENNEN

Memorandum Findings of Fact and Opinion

DRENNEN, Judge: Respondent determined a deficiency of $129.80 in petitioner's Federal income tax for 1967.

Two issues are presented for our decision: (1) Whether petitioner is entitled to a dependency exemption in 1967 for his*224 minor son, and (2) whether section 152(e) of the Internal Revenue Code of 1954, 1 is unconstitutional.

Findings of Fact

Some of the facts have been stipulated and are so found.

Petitioner, a single individual, resided in Cincinnati, Ohio, at the time he filed his petition herein. He filed his individual Federal income tax return for the taxable year 1967 with the district director of internal revenue, Cincinnati, Ohio.

On July 15, 1961, petitioner married Sandra A. Siegman. On April 1, 1962, a son, William Fred Estes Sowder (hereinafter referred to as William), was born of that marriage.

Petitioner and Sandra Sowder were divorced under a decree of divorce entered on September 18, 1963, in the court of Common Pleas, Domestic Relations Division, Hamilton County, Ohio. Under the decree of divorce Sandra Sowder was awarded custody of the child, with petitioner having reasonable visitation privileges, and petitioner was ordered to pay to the court $15 a week for the maintenance and support of the child.

On October 23, 1964, the*225 original decree of divorce was modified whereby petitioner was ordered to pay to the court $17 a week for the maintenance and support of William. During the year 1967 petitioner paid the sum of $816 for the support of William. Petitioner has not seen his former wife or son since the end of 1965.

Petitioner does not have a college education and in 1967 worked as a clerk and 452 lived modestly. Neither Sandra Sowder nor her parents have a college education; nor were her parents affluent people. Sandra Sowder did not have any working experience prior to her divorce from petitioner.

In his 1967 Federal income tax return petitioner claimed a dependency exemption for his minor son. Respondent disallowed the dependency exemption in the statutory notice of deficiency on the basis that petitioner had not satisfied the requirements of section 152(e). 2

*226 Opinion

The basic issue for our decision is whether petitioner is entitled to a dependency exemption for his minor son for 1967.

Section 151(e) allows a taxpayer an exemption of $600 for each of his dependents (as defined in section 152). Section 152(a) defines the term "dependent" to include specified individuals (including a son) "over half of whose support, for the calendar year in which the taxable year of the taxpayer begins, was received from the taxpayer." In 1967, Congress, realizing the difficulties encountered as a result of the burden of proof in dependency exemption cases where the parents of the child were divorced or legally separated, enacted Pub. L. No. 90-78 (Aug. 31, 1967), which added section 152(e) to the Internal Revenue Code of 1954.

Section 152(e), limited to taxable years beginning after December 31, 1966, provides specific rules in the case of divorced or separated parents for determining which parent is entitled to the dependency exemption allowed by section 151(e) with respect to the children born of that marriage. If section 152(e) is applicable 3 (as it is here), it provides as a general rule that the parent who has custody of the child for the*227 greater portion of the year is entitled to the deduction. It further provides two exceptions whereby the noncustodial parent is entitled to the deduction. The first exceptio, contained in section 152(e)(2)(A)

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Related

Massachusetts v. Mellon
262 U.S. 447 (Supreme Court, 1923)
Cobb v. Commissioner
28 T.C. 595 (U.S. Tax Court, 1957)
Milgroom v. Commissioner
31 T.C. 1256 (U.S. Tax Court, 1959)
Mendel v. Commissioner
41 T.C. 32 (U.S. Tax Court, 1963)

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Bluebook (online)
1971 T.C. Memo. 104, 30 T.C.M. 451, 1971 Tax Ct. Memo LEXIS 222, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sowder-v-commissioner-tax-1971.