Legal Opinion

Cramer v. Commissioner

United States Tax Court

Decided March 29, 1971No. Docket No. 5030-69PublishedCited by 26 opinions

1. Petitioner furnished more than half of the support of her son and is, therefore, entitled to a dependency exemption deduction for him for 1966. Secs. 151, 152, I.R.C. 1954. 2. Real property taxes for 1965 and 1966 on a residence owned by petitioner's mother were not imposed upon petitioner and are not deductible by her under sec. 164(a), I.R.C. 1954. 3. Real property taxes for 1964 and 1965 on a residence, sold in 1961 under a land sale contract on which the purchaser had…

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1. Petitioner furnished more than half of the support of her son and is, therefore, entitled to a dependency exemption deduction for him for 1966. Secs. 151, 152, I.R.C. 1954. 2. Real property taxes for 1965 and 1966 on a residence owned by petitioner's mother were not imposed upon petitioner and are not deductible by her under sec. 164(a), I.R.C. 1954. 3. Real property taxes for 1964 and 1965 on a residence, sold in 1961 under a land sale contract on which the purchaser had become delinquent, were assessed to petitioner under a Michigan statute and are deductible under sec. 164(a), I.R.C.…

1Opinion of the Court

Featheestox, Judge:

Respondent determined deficiencies in petitioner’s income tax for 1964,1965, and 1966 in the amounts of $257.62, $561.21, and $594.22, respectively. The issues presented for decision are:(1) Whether petitioner, during 1966, furnished more than one-half of the support of her son, Brian, within the meaning of section 152(a) ;1(2) "Whether the taxes which petitioner paid on certain real property during 1965 and 1966 are deductible under section 164;(3) Whether the expenses which petitioner incurred during 1966 in repossessing, reconditioning, and reselling her former residence…

2Cases cited21 opinions

  1. Magruder v. SuppleeSupreme Court of the United States · 1942
  2. Vance v. CommissionerUnited States Tax Court · 1961
  3. Elliott v. CommissionerUnited States Tax Court · 1963
  4. Alison v. United StatesSupreme Court of the United States · 1952
  5. Gilken Corporation v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1949

16 more not listed; retrieve them via the Exa API.

3Cited by26 opinions

  1. Hynes v. CommissionerUnited States Tax Court · 1980
  2. MANNING v. COMMISSIONERUnited States Tax Court · 1993
  3. Huey v. CommissionerUnited States Tax Court · 1985
  4. Lapin v. CommissionerUnited States Tax Court · 1990
  5. Tuer v. CommissionerUnited States Tax Court · 1983

21 more not listed; retrieve them via the Exa API.

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