Rivers v. Commissioner
United States Tax Court
Held, that where petitioner in a case involving dependency exemptions for minor children fails to establish the total cost of their support from all sources, he has failed in his proof even though he has shown the full amount expended by him for their support.
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Held, that where petitioner in a case involving dependency exemptions for minor children fails to establish the total cost of their support from all sources, he has failed in his proof even though he has shown the full amount expended by him for their support. Held, further, that this Court will not determine the total amount of support rendered dependents under the principle of Cohan v. Commissioner, 39 F. 2d 540. Held, further, an amount expended for tuition in parochial schools is an amount to be considered in determining total cost of support of minor children. Martha J. Blyth, 21 T.C.…
1Opinion of the Court
Withey, Judge:
A deficiency in the income tax of the petitioner for 1954 has been determined by the respondent in the amount of $264.
The only issue before us is whether the respondent has erred in disallowing the dependency exemptions taken by the petitioner in his income tax return for the taxable year 1954 with respect to his two minor children, Marilyn Rivers and Bernard Rivers, Jr.
FINDINGS OF. FACT.
Such facts as have been stipulated are found accordingly.
Petitioner is an individual, residing in Milwaukee, Wisconsin, who filed his Federal income tax return for the year 1954 with the…
2Cases cited2 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Blyth v. CommissionerUnited States Tax Court · 1953
3Cited by66 opinions
- Stafford v. CommissionerUnited States Tax Court · 1966
- Commissioner of Internal Revenue v. Walter H. Mendel and Lillian Mendel, Walter H. Mendel and Lillian Mendel v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1965
- Brown v. CommissionerUnited States Tax Court · 1967
- Seraydar v. CommissionerUnited States Tax Court · 1968
- McKay v. CommissionerUnited States Tax Court · 1960
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