De La Garza v. Commissioner
United States Tax Court
Held, although a multiple-support agreement was executed pursuant to section 152(c), I.R.C. 1954, the petitioner is not entitled to a dependency exemption for her sister where the sister contributed an amount ($ 409.71) to a common family fund used for the support of all members of the household which was greater than one-half of the total expenditure ($ 678.80) from the common fund for the sister's support.
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined a deficiency in income tax against the petitioner for the year 1962 in the amount of $120. The only issue for decision is whether the petitioner is entitled to claim her sister, Pauline, as a dependent under the provisions of sections 151 and 152,1.R.C. 1954, for the year 1962.
This case is fully stipulated. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
Estela De La Garza (hereafter called petitioner) resides at 3819 Eldridge, San Antonio, Tex. Petitioner, using her maiden name of Estela Alvarez,…
2Cases cited2 opinions
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- Collins v. CommissionerUnited States Tax Court · 1958
3Cited by16 opinions
- Betty Bell Huelsman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1969
- Estella De La Garza v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Meenk v. CommissionerUnited States Tax Court · 1970
- Scarangella v. CommissionerUnited States Tax Court · 1969
- Betty Bell Huelsman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1969
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