Legal Opinion

McCauley v. Commissioner

United States Tax Court

Decided April 12, 1971No. Docket No. 4425-69SCPublishedCited by 3 opinions

Petitioner's daughter received funds from scholarships, student loans, and earnings, as well as contributions from petitioner, which she used for her support during 1966. Held, the amounts received as student loans and earnings are not to be disregarded under sec. 152(d), I.R.C. 1954, in computing the amount of the daughter's total support.

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Petitioner's daughter received funds from scholarships, student loans, and earnings, as well as contributions from petitioner, which she used for her support during 1966. Held, the amounts received as student loans and earnings are not to be disregarded under sec. 152(d), I.R.C. 1954, in computing the amount of the daughter's total support. Consequently, petitioner failed to establish that he contributed over half of his daughter's support during 1966, and is not entitled to a dependency exemption deduction for her for that year under secs. 151, 152, I.R.C. 1954.

1Opinion of the Court

Featherston, Judge:

Respondent determined a deficiency in petitioner’s Federal income tax for 1966 in the amount of $747.79. Concessions have been made by both parties, and the only issue presented for decision is whether, within the meaning of section 152,1 petitioner furnished over half of the support of his daughter during 1966.

FINDINGS OF FACT

Philip J. McCauley was a legal resident of El Paso, Tex., at the time he filed his petition. He filed his Federal income tax return with the district director of internal revenue, Austin, Tex.

During 1966, petitioner’s daughter, Nancy McCauley…

2Cases cited4 opinions

  1. Bingler v. JohnsonSupreme Court of the United States · 1969
  2. Proskey v. CommissionerUnited States Tax Court · 1969
  3. Seraydar v. CommissionerUnited States Tax Court · 1968
  4. Horne v. CommissionerUnited States Tax Court · 1969

3Cited by3 opinions

  1. Williams v. CommissionerUnited States Tax Court · 1994
  2. Douglas Lemark Burse v. CommissionerUnited States Tax Court · 2014
  3. McCauley v. CommissionerUnited States Tax Court · 1971

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