Limpert v. Commissioner
United States Tax Court
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
Forrester, Judge:
Respondent determined deficiencies in petitioner’s income tax for the calendar years 1957 and 1958 in the amounts of $122.64 and $124.65, respectively. The issues before us are (1) whether amounts expended by petitioner in supporting her mother who in turn cared for petitioner’s son, thus enabling petitioner to be gainfully employed, are to be considered in determining whether or not petitioner has furnished over half of the support of her son, and (2) if so, whether petitioner may deduct up to $600 of such amounts each year as child care deductions, she having waived the…
2Cases cited4 opinions
- Lustig v. CommissionerUnited States Tax Court · 1958
- Massey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1931
- Bombarger v. CommissionerUnited States Tax Court · 1958
- Paul Lustig v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Halina LustigCourt of Appeals for the Ninth Circuit · 1960
3Cited by5 opinions
- Brown v. CommissionerUnited States Tax Court · 1979
- Brown v. CommissionerUnited States Tax Court · 1979
- Bye v. CommissionerUnited States Tax Court · 1972
- Limpert v. CommissionerUnited States Tax Court · 1961
- Williams v. CommissionerUnited States Tax Court · 1968