De La Garza v. COMMISSIONER OF INTERNAL REVENUE
| Decision Date | 02 June 1967 |
| Docket Number | No. 24220.,24220. |
| Parties | Estella DE LA GARZA, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. |
| Court | U.S. Court of Appeals — Fifth Circuit |
Stanley Schoenbaum, San Antonio, Tex., for petitioner.
Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, J. Nicholas McGrath, Gilbert E. Andrews, J. Edward Shillingburg, Richard C. Pugh, Jeanine Jacobs, Attys., Dept. of Justice, Lester R. Uretz, Chief Counsel, IRS., Eugene F. Collela, Atty., IRS., Washington, D. C., for respondent.
Before BELL, GODBOLD and DYER, Circuit Judges.
Petitioner seeks a review of a decision of the Tax Court1 sustaining a deficiency in her federal income tax for the taxable year 1962. The Tax Court held that although a multiple support agreement was executed pursuant to Section 152 (c), Internal Revenue Code 1954, the petitioner is not entitled to a dependency exemption for her sister where the sister contributed $409.71 to a common family fund used for the support of all members of the household which was greater than one-half of the total expenditure of $678.80 from the common fund for the sister's support.
1 46 T.C. 446.
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...grant relief to petitioner, however distasteful the result herein may appear. De La Garza, 46 T.C. 446 (1966), affirmed per curiam 378 F.2d 32 (C.A. 5, 1967). All we can do is emphasize what we said in Scudder, 48 T.C. at p. Although we have much sympathy for petitioner\'s unhappy situation......
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...circumstances. See De La Garza v. Commissioner [Dec. 28,015], 46 T.C. 446, 449-450 (1966), affd. [67-2 USTC ¶ 9484] per curiam 378 F.2d 32 (5th Cir. 1967). (8) Child Care Petitioner claimed a $290 child care credit for the taxable year 1985 based on $1,115 allegedly paid for the care of thr......
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Sumner v. Commissioner, Docket No. 1941-68.
...which each child has in effect supplied. Estela De La Garza Dec. 28,015, 46 T. C. 446 (1966), affirmed per curiam 67-2 USTC ¶ 9484 378 F. 2d 32 (C. A. 5, 1967). During the course of the trial of this case, Mary testified that she took on the responsibility of managing the family's financial......