Estella De La Garza v. Commissioner of Internal Revenue

PER CURIAM: Petitioner seeks a review of a decision of the Tax Court 1 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. The Tax Court properly interpreted the applicable provisions of the code and regulations and its decision is Affirmed. Footnotes [1] 46 T.C. 446.