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BAYLEY v. COMMISSIONER

Docket No. 64616.

35 T.C. 288 (1960)

JOHN F. AND RUTH BAYLEY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 18, 1960.

Attorney(s) appearing for the Case

J. Gilmer Blackburn, Esq., for the petitioners.

Harold G. Clark, Jr., Esq., for the respondent.

PIERCE, Judge:

The respondent determined a deficiency in petitioners' income taxes for the calendar year 1954 in the amount of $1,266.90. The issues for decision are:

[35 T.C. 289]
1. Was the petitioners' son a "full-time student at an educational institution" during each of 5 calendar months in the year 1954, within the meaning of section 151(e) of the Internal Revenue Code of 1954, so as to entitle petitioners to a dependency...

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