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Estella DE LA GARZA, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

PER CURIAM:

Petitioner seeks a review of a decision of the Tax Court sustaining a deficiency in her federal income tax for the taxable year 1962. The Tax Court held that although a multiple support agreement was executed pursuant to Section 152(c), Internal Revenue Code 1954, the petitioner is not entitled to a dependency exemption for her sister where the sister contributed $409.71 to a common family fund used for the support of all members of the household which was greater than one-half of the total expenditure of $678.80 from the common fund for the sister's support.

46 T.C. 446.

The Tax Court properly interpreted the applicable provisions of the code and regulations and its decision is

Affirmed.

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DE LA GARZA v. COMMISSIONER OF INTERNAL REVENUE
(Jun 2, 1967)