Legal Opinion

Limpert v. Commissioner

United States Tax Court

Decided December 15, 1961No. Docket No. 86361Published

Petitioner defrayed a substantial portion of her mother's living expenses so that the mother would live in petitioner's home and care for petitioner's son. Held: 1. Petitioner is entitled to a deduction for her son, Gregory, since she may count such moneys as a part of the cost of Gregory's support.

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Petitioner defrayed a substantial portion of her mother's living expenses so that the mother would live in petitioner's home and care for petitioner's son. Held: 1. Petitioner is entitled to a deduction for her son, Gregory, since she may count such moneys as a part of the cost of Gregory's support. Thomas Lovett, 18 T.C. 477, acq. 1952-2 C.B. 2, followed. 2. Deductions for child care expenses are deductible under section 214, I.R.C. 1954, even though an erroneous deduction under section 151 was claimed by taxpayer and not challenged by respondent. 3. Deduction for petitioner's mother as a…

1Opinion of the Court

Dorothy H. Limpert, Petitioner, v. Commissioner of Internal Revenue, Respondent

Limpert v. Commissioner

Docket No. 86361

United States Tax Court

37 T.C. 447; 1961 U.S. Tax Ct. LEXIS 14;

December 15, 1961, Filed

Decision will be entered under Rule 50.

Petitioner defrayed a substantial portion of her mother's living expenses so that the mother would live in petitioner's home and care for petitioner's son. Held:

1. Petitioner is entitled to a deduction for her son, Gregory, since she may count such moneys as a part of the cost of Gregory's support. Thomas Lovett, 18 T.C. 477, acq. 1952-2 C.B. 2,…

2Cases cited5 opinions

  1. Lustig v. CommissionerUnited States Tax Court · 1958
  2. Massey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1931
  3. Bombarger v. CommissionerUnited States Tax Court · 1958
  4. Limpert v. CommissionerUnited States Tax Court · 1961
  5. Paul Lustig v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Halina LustigCourt of Appeals for the Ninth Circuit · 1960

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