Legal Opinion

Cobb v. Commissioner

United States Tax Court

Decided May 31, 1957No. Docket No. 61219PublishedCited by 28 opinions

Held, under the facts, that petitioner furnished more than one-half the cost of the support of his two minor children during the taxable year 1954, and is entitled to the credit for dependents pursuant to the provisions of sections 151 and 152, I. R. C. 1954.

1Opinion of the Court

OPINION.

LeMure, Judge:

The only question presented is the factual one as to whether petitioner furnished more than one-half the cost of the support of his two children in 1954. The applicable statutory provisions are contained in sections 151 and 152 of the Internal Revenue Code of 1954.1 So far as pertinent here, the foregoing provisions of the 1954 Code are the same as those contained in section 25 (b) of the 1939 Code.

The burden is upon petitioner to establish that in the taxable year involved the amounts furnished constitute more than one-half the cost of the support of the dependents for…

2Cited by28 opinions

  1. Vance v. CommissionerUnited States Tax Court · 1961
  2. Stafford v. CommissionerUnited States Tax Court · 1966
  3. Commissioner of Internal Revenue v. Walter H. Mendel and Lillian Mendel, Walter H. Mendel and Lillian Mendel v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1965
  4. Brown v. CommissionerUnited States Tax Court · 1967
  5. Boettiger v. CommissionerUnited States Tax Court · 1958

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