# Robinson v. Commissioner

> United States Tax Court · December 31, 1968 · 51 T.C. 520

URL: https://www.frixlaw.com/law-library/cases/4481152

## Case

- **Full name:** John Robinson v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** December 31, 1968
- **Citations:** 51 T.C. 520; 1968 U.S. Tax Ct. LEXIS 1
- **Precedential status:** Published
- **Opinion:** Concurrence by Simpson
- **Judges:** Simpson,Featherston,Irwin
- **Cited by:** 34 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4481152

## Opinion text

Simpson, /., concurring: I agree with the majority in allowing the taxpayer head-of-household treatment, but I wish to express my reasons for reaching that conclusion.
In 1954, the law was changed to allow a taxpayer head-of-household treatment when he maintained his parents in a separate household. Our question is in what kind of household must the parent be maintained.
In referring to the provisions relating to head-of-household tax treatment, the committee reports frequently use the term “home” as a synonym for “household.” H. Rept. No. 1337, to accompany H.R. 8300 (Pub. L. No. 591), 83d Cong., 2d Sess., p. 5 (1954); S. Rept. No. 1622, to accompany H.R. 8300 (Pub. L. No. 591), 83d Cong., 2d Sess., pp. 4, 5 (1954). Thus, Congress contemplated that the taxpayer could qualify for head-of-household treatment if he provided a home for his parents. But was the term “home” intended to refer only to a house or an apartment, or was it intended to also include sleeping rooms in such, places as nursing homes or homes for the aged ? I can perceive no reason for distinguishing between an efficiency apartment and a sleeping room. In some situations, the sleeping room might be the more suitable home for the parent — and the more burdensome for the taxpayer to provide. For these reasons I conclude that Congress intended to include rest home accommodations within the meaning of “household.”
Featherston and iRwiN, JJagree with this concurring opinion.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4481152. Public record. Not legal advice.