Tilney v. Commissioner of Internal Revenue

182 F.2d 1009, 39 A.F.T.R. (P-H) 611, 1950 U.S. App. LEXIS 3976
CourtCourt of Appeals for the Fifth Circuit
DecidedJune 23, 1950
Docket13139_1
StatusPublished
Cited by1 cases

This text of 182 F.2d 1009 (Tilney 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.

Bluebook
Tilney v. Commissioner of Internal Revenue, 182 F.2d 1009, 39 A.F.T.R. (P-H) 611, 1950 U.S. App. LEXIS 3976 (5th Cir. 1950).

Opinion

PER CURIAM.

Sustaining the Commissioner’s determination, the Tax Court held on the pleadings that petitioner was not entitled to deductions on account of three dependents, the minor children of a deceased nephew of the taxpayer, actually residing with, and actually dependent upon, her for their support.

Petitioner, agreeing that the dependents for whom she claimed deductions are not named in the definition of dependents in Sec. 25(b) (3) of the Internal Revenue Code, as amended, 26 U.S.C.A. § 25(b) (3),. is here insisting that those definitions are not exclusive but only illustrative, and that the dependents for whom she claims deductions come within its principle.

We cannot agree. The judgment of the Tax Court was right. It is

Affirmed.

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Related

Bye v. Commissioner
1972 T.C. Memo. 57 (U.S. Tax Court, 1972)

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Bluebook (online)
182 F.2d 1009, 39 A.F.T.R. (P-H) 611, 1950 U.S. App. LEXIS 3976, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tilney-v-commissioner-of-internal-revenue-ca5-1950.