Memorandum Findings of Fact and Opinion
TIETJENS, Judge: A contested deficiency of $319.50 in income tax for 1948 is here involved.
The only question for decision is whether petitioner is entitled to dependency credits for his father and mother for that year.
Findings of Fact
Petitioner is an individual who resided in Lowell, Massachusetts during 1948 and who filed his return for that year with the Collector for the District of Massachusetts.
During the entire year 1948 petitioner lived at home with his mother. The mother had no income from any source and received her entire support from petitioner.
During the same period petitioner's father was an inmate of Monson State Hospital. Petitioner did not pay any of his father's medical, hospital, or other expenses during 1948 and did not contribute over half the support of his father for 1948.
Opinion
Petitioner and his mother appeared as the only witnesses and, based on their testimony, this case was decided from the bench. In accordance with our findings of fact we hold*407 that petitioner was entitled to a dependency credit for his mother, but not for his father for 1948. Because we do not have sufficient facts in the record before us to determine the correct deficiency,
Decision will be entered under Rule 50.