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SCARANGELLA v. C. I. R.

No. 17936.

418 F.2d 228 (1969)

Frank SCARANGELLA, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals Third Circuit.

Decided November 19, 1969.

Attorney(s) appearing for the Case

Frank Scarangella, pro se.

Leonard J. Henzke, Atty., Dept. of Justice, Tax Division, Lee A. Jackson, Thomas L. Stapleton, Attys., Dept. of Justice, Washington, D. C., Johnnie M. Walters, Asst. Atty. Gen., for appellee.

Before MARIS, SEITZ and STAHL, Circuit Judges.

OPINION OF THE COURT

PER CURIAM.

Appellant-taxpayer claims a dependency exemption for his aged mother for the year 1965, even though she had gross income during that year in excess of $600. Appellant's mother owned the home in which she and her son lived, and she leased a portion of the house in that year for rental payments totaling $860. The Internal Revenue Service and the Tax Court denied the taxpayer's claim for a dependency exemption.

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