CUNNINGHAM v. COMMISSIONER

Docket No. 41990.

22 T.C. 906 (1954)

ALLAN CUNNINGHAM AND MARY CUNNINGHAM, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 15, 1954.


Attorney(s) appearing for the Case

Allan Cunningham, pro se.

Hugh B. Muir, Esq., for the respondent.


The respondent determined a deficiency in the income tax of petitioners for the year 1948 in the amount of $487.04.

The issues are:

(1) Did petitioner Allan Cunningham provide more than one-half of the support of his mother during the year 1948 so as to entitle him to a credit against net income under the provisions of section 25 (b) (1) (D) of the Internal Revenue Code?

(2) Are the petitioners entitled to deduct as trade or business expenses under...

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