Hahn v. Commissioner
United States Tax Court
Exemption -- Dependent -- Gross Income -- Support -- Sec. 25 (b) (1) (C) and (3), I. R. C. -- No exemption for a dependent is proper where it does not appear that the gross income of the alleged dependent was less than $ 500 or that she received more than one-half of her support from the petitioner.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner contends that Exilda had gross income in excess of $500 for each year and could not be a dependent under section 25 (b) (1) (C) of the Code. The petitioner argues that the gross income to which the Commissioner refers belonged to a partnership and was not gross income of the partners within the meaning of section 25 (b) (1) (C). The petitioner testified that there was no written agreement of partnership and “there aren’t any terms” of a partnership agreement. A fair inference to be drawn from all of her testimony is that her only basis for thinking that…
2Cases cited3 opinions
- Commissioner of Internal Rev. v. Appleby's EstateCourt of Appeals for the Second Circuit · 1941
- Langer v. CommissionerUnited States Tax Court · 1951
- Coffin v. United StatesDistrict Court, S.D. Alabama · 1954
3Cited by35 opinions
- Madison Gas and Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
- Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
- Blarek v. CommissionerUnited States Tax Court · 1955
- Alfred H. Turecamo and Frances M. Turecamo v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1977
- Turecamo v. CommissionerUnited States Tax Court · 1975
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