Ward Gulvin and Estate of Dorothy Gulvin, Deceased v. Commissioner of Internal Revenue

Taxpayers appeal from the Tax Court’s decision disallowing their claimed dependency exemption for the 1973 tax year for five of their children who lived in foster homes. The key question for an income tax deduction for a dependent child is whether over half of the child’s support was received from taxpayer. Taxpayers contend that, although the state is paying for their children’s foster care,- the husband’s estate will be liable to the state under Florida law for such state expenditures and therefore the state’s public support payments should be treated as having been received from the…