John H. Gooch v. Commissioner of Internal Revenue

LINDLEY, Circuit Judge.

In this petition for review, the taxpayer assails the decision of the Tax Court to the effect that petitioner was not entitled to a credit against his net income under Section 25(b) (1) (D) of the Internal Revenue Code of 1939, 26 U.S.C. § 25, for a dependency exemption on account of his mother. Petitioner, in his return for 1950, claimed a dependency credit by reason of his contribution to her support. In 1950, she received, as Ler proportionate share of the rents of a house and two farms and from dividends and interest, a total of $794.44. This gross income did not…