Gestrich v. Commissioner
United States Tax Court
Liens were placed on petitioner's real estate with respect to support provided by the county to his minor son who was placed in a foster home. Petitioner claimed dependency exemptions for this son on the basis that he had provided over half of his son's support by way of these liens. Held, an unfulfilled obligation of support is insufficient to justify a dependency exemption. Held, further, petitioner was in the trade or business of being an author.
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Liens were placed on petitioner's real estate with respect to support provided by the county to his minor son who was placed in a foster home. Petitioner claimed dependency exemptions for this son on the basis that he had provided over half of his son's support by way of these liens. Held, an unfulfilled obligation of support is insufficient to justify a dependency exemption. Held, further, petitioner was in the trade or business of being an author. Held, further, home office and business expense deductions determined.
1Opinion of the Court
Sterrett, Judge:
By letter dated August 8, 1978, respondent determined deficiencies in income taxes due from petitioner Robert T. Gestrich in the amount of $529.44 for his taxable year ended December 31, 1975, and $865 for his taxable year ended December 31, 1976. By a separate letter dated June 27, 1979, respondent determined a deficiency in income taxes due from petitioner in the amount of $112 for his taxable year ended December 31, 1977. Docket No. 11787-78, filed with respect to respondent’s notice of deficiency dated August 8, 1978, and docket No. 12621-79, filed with respect to…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Sharon v. CommissionerUnited States Tax Court · 1976
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- Ripley v. CommissionerUnited States Tax Court · 1987
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