Legal Opinion

Kishner v. Commissioner

United States Board of Tax Appeals

Decided July 31, 1940No. Docket No. 93434Published

HEAD OF FAMILY - PERSONAL EXEMPTION CREDIT DENIED. - During 1936 and for several years prior thereto, petitioner resided in Chicago, Illinois, where he was engaged in the practice of law. His parents resided in Philadelphia, Pennsylvania, where they owned their own home. Petitioner was substantially the sole support of his parents during the taxable year.

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HEAD OF FAMILY - PERSONAL EXEMPTION CREDIT DENIED. - During 1936 and for several years prior thereto, petitioner resided in Chicago, Illinois, where he was engaged in the practice of law. His parents resided in Philadelphia, Pennsylvania, where they owned their own home. Petitioner was substantially the sole support of his parents during the taxable year. Held, there being no reasonable necessity for petitioner to maintain his parents in a separate household, petitioner was not the head of a family within the meaning of section 25(b), Revenue Act of 1936, and art. 25-4, Regulations 94.

1Opinion of the Court

HARRY P. KISHNER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Kishner v. Commissioner

Docket No. 93434.

United States Board of Tax Appeals

42 B.T.A. 456; 1940 BTA LEXIS 1004;

July 31, 1940, Promulgated

HEAD OF FAMILY - PERSONAL EXEMPTION CREDIT DENIED. - During 1936 and for several years prior thereto, petitioner resided in Chicago, Illinois, where he was engaged in the practice of law. His parents resided in Philadelphia, Pennsylvania, where they owned their own home. Petitioner was substantially the sole support of his parents during the taxable year. Held, there being no…

2Cases cited1 opinion

  1. Kishner v. CommissionerUnited States Board of Tax Appeals · 1940

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