Legal Opinion

Reed v. Commissioner

United States Tax Court

Decided July 29, 1968No. Docket No. 4476-66PublishedCited by 2 opinions

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

Mulroney, Judge:

Respondent determined deficiencies in petitioners’ 1964 income tax in tfie amount of $357.17.

The issue is whether petitioners are allowed exemption deductions of $600 for each of two “foster” children under the provisions of section 151 (e) (1), I.R.C. 1954.1

FINDINGS OF FACT

Some of the facts have been stipulated and they are found accordingly.

The petitioners, Edward A. Reed and Eloise A. Reed, whose legal residence at the time the petition herein was filed was Detroit, Mich., filed their joint Federal income tax return for the year 1964 with the district director of internal…

2Cases cited2 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

3Cited by2 opinions

  1. Galazin v. CommissionerUnited States Tax Court · 1979
  2. Reed v. CommissionerUnited States Tax Court · 1968

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