Bryant v. Commissioner
United States Tax Court
Held: Sec. 214(e)(4), I.R.C. 1954, which disallows a deduction for payments made to relatives described in paragraphs (1) through (8) of sec. 152(a), does not violate the due process clause of the Fifth Amendment to the Constitution. Accordingly, petitioner may not deduct the payments made to her niece and her mother for dependent care services.
1Opinion of the Court
OPINION
Chabot, Judge:
Respondent determined a deficiency of $318.09 in petitioner’s Federal income tax for 1975. The only issue presented for our consideration is the constitutionality of section 214(e)(4),1 as then in effect,2 which operated to disallow a deduction for amounts paid as dependent care services expenses to petitioner’s mother and petitioner’s niece.
All of the facts have been stipulated; the stipulation and the stipulated exhibits are incorporated herein by this reference.
When the petition in this case was filed, petitioner was a legal resident of Detroit, Mich.
During 1975,…
2Cases cited32 opinions
- Dandridge v. WilliamsSupreme Court of the United States · 1970
- McGowan v. MarylandSupreme Court of the United States · 1961
- Shapiro v. ThompsonSupreme Court of the United States · 1969
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Bolling v. SharpeSupreme Court of the United States · 1954
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3Cited by15 opinions
- Smith v. CommissionerUnited States Tax Court · 1981
- Kessler v. CommissionerUnited States Tax Court · 1986
- Sallies v. CommissionerUnited States Tax Court · 1984
- Estate of Lewis v. CommissionerUnited States Tax Court · 1980
- Bryant v. CommissionerUnited States Tax Court · 1979
10 more not listed; retrieve them via the Exa API.