Legal Opinion

Cramer v. Commissioner

United States Tax Court

Decided March 29, 1971No. Docket No. 5030-69Published

1. Petitioner furnished more than half of the support of her son and is, therefore, entitled to a dependency exemption deduction for him for 1966. Secs. 151, 152, I.R.C. 1954. 2. Real property taxes for 1965 and 1966 on a residence owned by petitioner's mother were not imposed upon petitioner and are not deductible by her under sec. 164(a), I.R.C. 1954. 3. Real property taxes for 1964 and 1965 on a residence, sold in 1961 under a land sale contract on which the purchaser had…

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1. Petitioner furnished more than half of the support of her son and is, therefore, entitled to a dependency exemption deduction for him for 1966. Secs. 151, 152, I.R.C. 1954. 2. Real property taxes for 1965 and 1966 on a residence owned by petitioner's mother were not imposed upon petitioner and are not deductible by her under sec. 164(a), I.R.C. 1954. 3. Real property taxes for 1964 and 1965 on a residence, sold in 1961 under a land sale contract on which the purchaser had become delinquent, were assessed to petitioner under a Michigan statute and are deductible under sec. 164(a), I.R.C.…

1Opinion of the Court

Virginia M. Cramer, Petitioner v. Commissioner of Internal Revenue, Respondent

Cramer v. Commissioner

Docket No. 5030-69

United States Tax Court

55 T.C. 1125; 1971 U.S. Tax Ct. LEXIS 162;

March 29, 1971, Filed

Decision will be entered under Rule 50.

1. Petitioner furnished more than half of the support of her son and is, therefore, entitled to a dependency exemption deduction for him for 1966. Secs. 151, 152, I.R.C. 1954.

2. Real property taxes for 1965 and 1966 on a residence owned by petitioner's mother were not imposed upon petitioner and are not deductible by her under sec. 164(a), I.R.C. 1954.

3.…

2Cases cited22 opinions

  1. Magruder v. SuppleeSupreme Court of the United States · 1942
  2. Vance v. CommissionerUnited States Tax Court · 1961
  3. Elliott v. CommissionerUnited States Tax Court · 1963
  4. Alison v. United StatesSupreme Court of the United States · 1952
  5. Gilken Corporation v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1949

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