Legal Opinion

Reed v. Commissioner

United States Tax Court

Decided July 29, 1968No. Docket No. 4476-66Published

Petitioners sought exemption deductions of $ 600 for each of two 18 year old boys who were full-time students and who each earned over $ 600 in the year in issue. The boys were petitioners' foster sons in that they were not petitioners' natural or adopted sons but they had been members of petitioners' household for several years and petitioners contributed over half the total support for the boys during the year in issue.

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Petitioners sought exemption deductions of $ 600 for each of two 18 year old boys who were full-time students and who each earned over $ 600 in the year in issue. The boys were petitioners' foster sons in that they were not petitioners' natural or adopted sons but they had been members of petitioners' household for several years and petitioners contributed over half the total support for the boys during the year in issue. Also, the boys had not been placed in the home for adoption. Held: The boys did not qualify as petitioners' dependents under sec. 151(e)(1)(B), I.R.C. 1954, giving the…

1Opinion of the Court

Edward A. Reed and Eloise A. Reed, Petitioners v. Commissioner of Internal Revenue, Respondent

Reed v. Commissioner

Docket No. 4476-66

United States Tax Court

50 T.C. 630; 1968 U.S. Tax Ct. LEXIS 94;

July 29, 1968, Filed

Decision will be entered under Rule 50.

Petitioners sought exemption deductions of $ 600 for each of two 18 year old boys who were full-time students and who each earned over $ 600 in the year in issue. The boys were petitioners' foster sons in that they were not petitioners' natural or adopted sons but they had been members of petitioners' household for several years and…

2Cases cited3 opinions

  1. Harrison v. CommissionerUnited States Tax Court · 1952
  2. Marie Emily Flanagan, Daughter and of the Estate of Pauline C. Mott v. Railroad Retirement BoardCourt of Appeals for the Third Circuit · 1964
  3. Reed v. CommissionerUnited States Tax Court · 1968

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