Williams v. Commissioner
United States Tax Court
Petitioner, a widower, provided all the support for his adopted son and his son's family during the taxable years 1962, 1964, and 1965. Since 1957, petitioner and his son have not lived together in the same household or place of residence. From 1957 until May of 1965, petitioner has lived in hotel rooms at or near construction projects on which he was employed in various States and in Canada.
Read the full summary
Petitioner, a widower, provided all the support for his adopted son and his son's family during the taxable years 1962, 1964, and 1965. Since 1957, petitioner and his son have not lived together in the same household or place of residence. From 1957 until May of 1965, petitioner has lived in hotel rooms at or near construction projects on which he was employed in various States and in Canada. For a time in 1957, the son was employed on the same project as petitioner in Upper New York. They lived in different places. The son continued in this employment for 5 months after petitioner left.…
1Opinion of the Court
BRUCE, Judge:
Respondent determined deficiencies in the income tax of petitioner for calendar years as follows:
[[Image here]]
The sole issue for decision is whether, during the years involved, petitioner qualified for head-of-household rates of tax under section 1(b), I.R.C. 1954.
FINDINGS OF FACT
Petitioner is an umnarried individual whose residence was in Lakeside, Mont., at the time the petitions herein were filed. He filed timely income tax returns for the calendar years 1962, 1964, and 1965 with the district director of internal revenue at Omaha, Nebr.
In about 1945 petitioner and his wife…
2Cases cited6 opinions
- Clair Smith v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Grace v. CommissionerUnited States Tax Court · 1969
- Smith v. CommissionerUnited States Tax Court · 1963
- Hein v. CommissionerUnited States Tax Court · 1957
- Brown & Williamson Tobacco Corp. v. the S.S. AnghyraDistrict Court, E.D. Virginia · 1957
1 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Dobra v. CommissionerUnited States Tax Court · 1998
- John C. Muse v. United StatesCourt of Appeals for the Fourth Circuit · 1970
- Prendergast v. CommissionerUnited States Tax Court · 1972
- David B. Williams v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Dobra v. CommissionerUnited States Tax Court · 1998
8 more not listed; retrieve them via the Exa API.