Horne v. Commissioner
United States Tax Court
Held, that education is an item of support within the meaning of sec. 152(a) of the Internal Revenue Code of 1954. Held, further, that the petitioner has not shown that he provided over half of the support of his son during the taxable year 1965 and he is therefore not entitled to a dependency exemption for the son.
1Opinion of the Court
OPINION
Section 151 of the Internal Revenue Code of 1954 provides that in the case of an individual there shall be allowed as a deduction an exemption of $600 for each dependent whose gross income for the calendar year in which the taxable year of the taxpayer begins is less than $600 or who is a child of the taxpayer who has not attained the age of 19 or who is a student.1 Section 152(a) defines the term “dependent” as including a son of the taxpayer over half of whose support, for the calendar year in which the taxable year of the taxpayer begins, was received from the taxpayer.2
The…
2Cases cited5 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Brewster v. GageSupreme Court of the United States · 1930
- Rivers v. CommissionerUnited States Tax Court · 1960
- Blyth v. CommissionerUnited States Tax Court · 1953
3Cited by6 opinions
- McCauley v. CommissionerUnited States Tax Court · 1971
- Clark v. CommissionerUnited States Tax Court · 1981
- Horne v. CommissionerUnited States Tax Court · 1969
- Lewis v. CommissionerUnited States Tax Court · 1969
- McCauley v. CommissionerUnited States Tax Court · 1971
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