Legal Opinion

McCauley v. Commissioner

United States Tax Court

Decided April 12, 1971No. Docket No. 4425-69SCPublished

Petitioner's daughter received funds from scholarships, student loans, and earnings, as well as contributions from petitioner, which she used for her support during 1966. Held, the amounts received as student loans and earnings are not to be disregarded under sec. 152(d), I.R.C. 1954, in computing the amount of the daughter's total support.

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Petitioner's daughter received funds from scholarships, student loans, and earnings, as well as contributions from petitioner, which she used for her support during 1966. Held, the amounts received as student loans and earnings are not to be disregarded under sec. 152(d), I.R.C. 1954, in computing the amount of the daughter's total support. Consequently, petitioner failed to establish that he contributed over half of his daughter's support during 1966, and is not entitled to a dependency exemption deduction for her for that year under secs. 151, 152, I.R.C. 1954.

1Opinion of the Court

Philip J. McCauley, Petitioner v. Commissioner of Internal Revenue, Respondent

McCauley v. Commissioner

Docket No. 4425-69SC

United States Tax Court

56 T.C. 48; 1971 U.S. Tax Ct. LEXIS 152;

April 12, 1971, Filed

Decisions will be entered under Rule 50.

Petitioner's daughter received funds from scholarships, student loans, and earnings, as well as contributions from petitioner, which she used for her support during 1966. Held, the amounts received as student loans and earnings are not to be disregarded under sec. 152(d), I.R.C. 1954, in computing the amount of the daughter's total support.…

2Cases cited5 opinions

  1. Bingler v. JohnsonSupreme Court of the United States · 1969
  2. Proskey v. CommissionerUnited States Tax Court · 1969
  3. Seraydar v. CommissionerUnited States Tax Court · 1968
  4. Horne v. CommissionerUnited States Tax Court · 1969
  5. McCauley v. CommissionerUnited States Tax Court · 1971

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