Legal Opinion

Bryant v. Commissioner

United States Tax Court

Decided August 3, 1979No. Docket No. 9631-77Published

Held: Sec. 214(e)(4), I.R.C. 1954, which disallows a deduction for payments made to relatives described in paragraphs (1) through (8) of sec. 152(a), does not violate the due process clause of the Fifth Amendment to the Constitution. Accordingly, petitioner may not deduct the payments made to her niece and her mother for dependent care services.

1Opinion of the Court

Helen C. Bryant, Petitioner v. Commissioner of Internal Revenue, Respondent

Bryant v. Commissioner

Docket No. 9631-77

United States Tax Court

72 T.C. 757; 1979 U.S. Tax Ct. LEXIS 82;

August 3, 1979, Filed

Decision will be entered for the respondent.

Held: Sec. 214(e)(4), I.R.C. 1954, which disallows a deduction for payments made to relatives described in paragraphs (1) through (8) of sec. 152(a), does not violate the due process clause of the Fifth Amendment to the Constitution. Accordingly, petitioner may not deduct the payments made to her niece and her mother for dependent care services.

Jimmylee…

2Cases cited33 opinions

  1. Dandridge v. WilliamsSupreme Court of the United States · 1970
  2. McGowan v. MarylandSupreme Court of the United States · 1961
  3. Shapiro v. ThompsonSupreme Court of the United States · 1969
  4. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  5. Bolling v. SharpeSupreme Court of the United States · 1954

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