Hein v. Commissioner
United States Tax Court
1. Held, that the basic purpose and intent of section 12 (c), I. R. C. 1939, which allows "head-of-household" status in certain situations, is to extend to unmarried householders some of the benefits of the income splitting which is available to married couples -- if the household, in addition to being the taxpayer's home, is also the "principal" place of abode of his unmarried child, stepchild, grandchild, or any other person who qualifies as his "dependent" and with whom,…
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1. Held, that the basic purpose and intent of section 12 (c), I. R. C. 1939, which allows "head-of-household" status in certain situations, is to extend to unmarried householders some of the benefits of the income splitting which is available to married couples -- if the household, in addition to being the taxpayer's home, is also the "principal" place of abode of his unmarried child, stepchild, grandchild, or any other person who qualifies as his "dependent" and with whom, as such, he shares his income. 2. Held, further, that the benefits of such statute are available to the petitioner,…
1Opinion of the Court
OPINION..
Pierce, Judge:
The respondent determined a deficiency in tbe income tax of tbe petitioner for tbe calendar'year 1952, in tbe amount of $560.47. Petitioner contends that the tax has been overpaid.
Tbe sole issue for decision is whether, for tbe taxable year 1952, the petitioner qualified as “bead of a household,” within the meaning of section 12 (c) 1 of the Internal Revenue Code (1939). The only other issue raised in the pleadings was abandoned by petitioner, at the trial.
The case was submitted on a written stipulation of facts, together with certain exhibits that were attached and…
2Cited by23 opinions
- Robinson v. CommissionerUnited States Tax Court · 1968
- Rowe v. Comm'rUnited States Tax Court · 2007
- Prendergast v. CommissionerUnited States Tax Court · 1972
- Williams v. CommissionerUnited States Tax Court · 1969
- Laraia v. United StatesDistrict Court, D. Massachusetts · 1964
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