C. I. R. v. IDE

No. 14761.

335 F.2d 852 (1964)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Charles P. IDE and Martha M. Ide, Respondents.

United States Court of Appeals Third Circuit.

Decided July 15, 1964.


Attorney(s) appearing for the Case

J. Edward Shillingburg, Dept. of Justice, Tax Div., Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Attys., Dept. of Justice, Washington, D. C., on the brief), for petitioner.

Charles P. Ide, and Martha M. Ide, pro se.

Before BIGGS, Chief Judge, HASTIE, Circuit Judge, and KIRKPATRICK, District Judge.


HASTIE, Circuit Judge.

On this appeal we review a decision of the Tax Court which held, reversing a ruling of the Commissioner, that there was no deficiency in the taxpayers' income tax return.

In their 1958 income tax return, the taxpayers, who are husband and wife, claimed their son, an undergraduate student at Cornell University, as a dependent and took an exemption for him. The Commissioner disallowed this exemption, ruling that the taxpayers had not provided...

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