Frank Markarian v. Commissioner of Internal Revenue

SWYGERT, Circuit Judge.

This appeal presents a construction of sections 151 and 152 of the Internal Revenue Code of 1954 1 and Treasury regulations issued thereunder. The question is whether the value of personal services rendered by a son to an aged mother, residing with him, is includible as an item of support under section 152. The section allows an exemption for a dependent, over one-half of whose support has been supplied by the taxpayer. The Commissioner of Internal Revenue determined that taxpayer Frank Markarian was not entitled to a dependency exemption for his mother for the taxable…