Shapiro v. Commissioner
United States Tax Court
54 T.C. 347 (1970)

- Written by Joe Cox, JD
Facts
Betty Shapiro (plaintiff) filed 1966 federal income taxes in which Betty claimed her son, Michael, as a dependent. The Commissioner of Internal Revenue (defendant) found a deficiency of $126.48 because Betty did not provide more than one-half of Michael’s total support for the year in question and, therefore, could not properly claim Michael as Betty’s dependent. Betty filed suit regarding the claimed dependency credit for Michael. The concern was Betty’s payment of $916.66 to send Michael to summer camp at Camp Wildwood in Bridgeton, Maine, for eight weeks in 1966. Betty paid $417 in 1966 and the remaining $499.66 in 1967. The government argued that the camp fees were not for Michael’s support. The Internal Revenue Code defined support as food, shelter, clothing, medical and dental care, education, and similar expenses. Other Internal Revenue guidance included recreation within the definition of support. The government argued that support amounted to necessities and that the camp fees were a luxury item not considered part of Michael’s support.
Rule of Law
Issue
Holding and Reasoning (Dawson, J.)
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