Legal Opinion

Smith v. Commissioner

United States Tax Court

Decided June 26, 1963No. Docket No. 93605PublishedCited by 27 opinions

Taxpayer maintains a household in Beverly Hills, Calif., and a household in Reno, Nev. The Beverly Hills household is the principal place of abode of taxpayer's dependent son. The Reno household is the residence, domicile, and principal place of abode of taxpayer. Held, taxpayer is not the head of a household within the meaning of section 1(b)(2), I.R.C. 1954.

1Opinion of the Court

OPINION

Mulronet, Judge:

The respondent determined deficiencies in petitioner’s income tax for the years 1956, 1957, and 1958 in the amounts of $16,383.26, $12,749.82, and $11,723.41, respectively.

The only issue presented is whether petitioner was entitled to compute her income tax at rates provided for head of a household.

All of the facts were stipulated and they are found accordingly.

We set forth below in numbered paragraphs (omitting paragraph 2 pertaining to an issue not involved) the stipulation filed by the parties :

1. The petitioner, Clair Smith, is an individual who for the taxable…

2Cited by27 opinions

  1. Grace v. CommissionerUnited States Tax Court · 1969
  2. Dobra v. CommissionerUnited States Tax Court · 1998
  3. Teeling v. CommissionerUnited States Tax Court · 1964
  4. Prendergast v. CommissionerUnited States Tax Court · 1972
  5. Williams v. CommissionerUnited States Tax Court · 1969

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