Legal Opinion

Carter v. Commissioner

United States Tax Court

Decided October 22, 1970No. Docket No. 5994-69SCPublishedCited by 13 opinions

Petitioner's grandmother received from the State old-age assistance payments and health insurance, the value of which, in the aggregate, exceeded the amount spent by petitioner on the support of his grandmother. However, the grandmother did not spend all the old-age assistance payments on her own support. Held, on the facts, petitioner provided over one-half the total support received by his grandmother in the taxable year 1967.

1Opinion of the Court

Stereett, Judge:

Respondent determined a deficiency of $412.29 in petitioner’s income tax for the taxable year 1967.

Certain of the adjustments set forth in the statutory notice have not been contested by the petitioners. Consequently there remains only one issue for decision: Whether petitioner, Eddie L. Carter, furnished more than half the total support of his paternal grandmother in 1967 so as to be allowed a deduction for personal exemption for his grandmother pursuant to section 151 of the Internal Revenue Code of 1954.1

FINDINGS OF FACT

Eddie L. Carter (hereinafter referred to as…

2Cases cited6 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Burnet v. HarmelSupreme Court of the United States · 1932
  3. Blarek v. CommissionerUnited States Tax Court · 1955
  4. Commissioner of Internal Revenue v. Thompson Et UxCourt of Appeals for the Tenth Circuit · 1951
  5. McKay v. CommissionerUnited States Tax Court · 1960

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

3Cited by13 opinions

  1. Alfred H. Turecamo and Frances M. Turecamo v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1977
  2. Archer v. CommissionerUnited States Tax Court · 1980
  3. Jewell v. Comm'rUnited States Tax Court · 1978
  4. Archer v. CommissionerUnited States Tax Court · 1980
  5. Archer v. CommissionerUnited States Tax Court · 1980

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

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