MORRELL v. COMMISSIONER OF INTERNAL REVENUE

No. 6955.

107 F.2d 34 (1939)

MORRELL v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

October 3, 1939.


Attorney(s) appearing for the Case

Wm. Cutler Thompson, of Washington, D. C., and Emanuel Friedman, of Philadelphia, Pa., for petitioner.

James W. Morris, Asst. Atty. Gen., and Sewall Key and Alexander Tucker, Sp. Assts. to Atty. Gen., for respondent.

Before BIGGS, MARIS, and CLARK, Circuit Judges.


CLARK, Circuit Judge.

The income tax has from its inception allowed the taxpayer some form of credit against net income for "dependents". The various departmental rulings and Board decisions on the question of the allowance of that credit all reflect a fundamental factual pattern. We invariably find the taxpayer seeking credit for the support of his relatives (generally from one to five in number). See Paul and Mertens, The Law of Federal Income Taxation, Sec. 30...

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