Zoltan v. Commissioner
United States Tax Court
During 1977 and 1978, petitioner was employed as an accountant, a job that required her absence from home approximately 55 hours per week. During the summer of 1977, petitioner sent her son, who was then 11 years old and concededly a qualifying individual as defined in sec. 44A(c)(1)(A), I.R.C. 1954, to an 8-week summer camp in Canada.
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During 1977 and 1978, petitioner was employed as an accountant, a job that required her absence from home approximately 55 hours per week. During the summer of 1977, petitioner sent her son, who was then 11 years old and concededly a qualifying individual as defined in sec. 44A(c)(1)(A), I.R.C. 1954, to an 8-week summer camp in Canada. Alternative forms of care available to petitioner would have cost between $ 1,000 and $ 1,320. Held, sending her son to camp enabled petitioner to work, and her primary concern was his protection and well-being, and, therefore, the entire $ 1,100 camp expense…
1Opinion of the Court
Edith W. Zoltan, Petitioner v. Commissioner of Internal Revenue, Respondent
Zoltan v. Commissioner
Docket No. 18977-80
United States Tax Court
79 T.C. 490; 1982 U.S. Tax Ct. LEXIS 39; 79 T.C. No. 31;
September 20, 1982, Filed
Decision will be entered under Rule 155.
During 1977 and 1978, petitioner was employed as an accountant, a job that required her absence from home approximately 55 hours per week. During the summer of 1977, petitioner sent her son, who was then 11 years old and concededly a qualifying individual as defined in sec. 44A(c)(1)(A), I.R.C. 1954, to an 8-week summer camp in Canada.…
Also in this document: Concurring in part, dissenting in part.
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Warner v. CommissionerUnited States Tax Court · 1978
- Brown v. CommissionerUnited States Tax Court · 1979
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