Milgroom v. Commissioner
United States Tax Court
1. Respondent disallowed exemptions claimed by petitioner on account of three children for the reason that he "failed to substantiate [his] claim to these dependency credits."
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1. Respondent disallowed exemptions claimed by petitioner on account of three children for the reason that he "failed to substantiate [his] claim to these dependency credits." Held, facts of record warrant conclusion that the children received more than one-half of their support from petitioner during the taxable year and that petitioner is entitled to such dependency credits. 2. During taxable year and prior to petitioner's divorce from his wife, petitioner and his wife sold their home, located in Massachusetts, to which they held title as tenants by the entirety. At the time of the sale,…
1Opinion of the Court
OPINION.
Kern, Judge:
The first question presented herein is whether petitioner is entitled to exemptions for his three children during the year 1953. The resolution of this question depends on whether the children received more than one-half of their support from petitioner during that year. Respondent disallowed the exemptions because petitioner, according to the deficiency notice, “failed to substantiate [his] claim to these dependency credits.” The only testimony adduced at the trial herein was that of petitioner. Neither party called other witnesses. There is nothing to cause us to…
2Cases cited6 opinions
- Pineo v. WhiteMassachusetts Supreme Judicial Court · 1946
- Licker v. GluskinMassachusetts Supreme Judicial Court · 1929
- Childs v. ChildsMassachusetts Supreme Judicial Court · 1935
- Nicodemus v. CommissionerUnited States Board of Tax Appeals · 1932
- Cooley v. CommissionerUnited States Board of Tax Appeals · 1933
1 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Stafford v. CommissionerUnited States Tax Court · 1966
- 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
- Brown v. CommissionerUnited States Tax Court · 1967
- Cramer v. CommissionerUnited States Tax Court · 1971
- Pillis v. CommissionerUnited States Tax Court · 1967
21 more not listed; retrieve them via the Exa API.