Tilney v. Commissioner of Internal Revenue
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.
Opinion
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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Cite This Page — Counsel Stack
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.