TOOR v. COMMISSIONER

Docket No. 104-76.

36 T.C.M. 1616 (1977)

T.C. Memo. 1977-399

Pir M. Toor v. Commissioner.

United States Tax Court.

Filed November 16, 1977.


Attorney(s) appearing for the Case

Robert H. Hishon, 1200 Citizens and Southern Nat'l Bank Bldg., Atlanta, Ga., for the petitioner. Terrell W. Dahlman and Stanley H. Smith, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency of $1,145 in petitioner's Federal income tax for calendar year 1973. Petitioner has conceded one of the issues raised in the pleadings, leaving for decision the following:

Whether petitioner's brother was a resident of the United States during the year 1973 so as to entitle petitioner to a deduction for a dependency exemption for his brother under the provisions...

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