Wedvik v. Commissioner
United States Tax Court
Petitioners claimed charitable contribution deductions for payments made to various Universal Life Churches and to a fund established and maintained by the Universal Life Church, Inc., of Modesto, California. However, all such payments were repaid to petitioners or to their own Universal Life Church. Held, petitioners are not entitled to a charitable contribution deduction because no actual contributions were made.
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Petitioners claimed charitable contribution deductions for payments made to various Universal Life Churches and to a fund established and maintained by the Universal Life Church, Inc., of Modesto, California. However, all such payments were repaid to petitioners or to their own Universal Life Church. Held, petitioners are not entitled to a charitable contribution deduction because no actual contributions were made. Sec. 170(a), I.R.C. 1954; Davis v. Commissioner, 81 T.C. 806 (1983), affd. without published opinion 767 F.2d 931 (9th Cir. 1985); Glynn v. Commissioner, 76 T.C. 116, 121-122…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income tax and additions to tax as follows:
Taxable Additions to tax
year Deficiency Sec. 6653(b)(1)1 Sec. 6653(b)(2)
1980 $5,479 $2,739.50 0
1981 6,691 3,345.50 0
1982 6,796 3,398.00 50% interest
due on $6,796
In his answer respondent alleged, as an alternative to the imposition of the additions to tax for fraud, that petitioners are liable for additions to tax under section 6653(a) and for damages under section 6673.
The issues presented are: (1) Whether petitioners are entitled to deduct alleged charitable contributions…
2Cases cited19 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Beaver v. CommissionerUnited States Tax Court · 1970
- Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968
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3Cited by38 opinions
- Allen v. CommissionerUnited States Tax Court · 1989
- Burwell v. CommissionerUnited States Tax Court · 1987
- Svedahl v. CommissionerUnited States Tax Court · 1987
- Dew v. CommissionerUnited States Tax Court · 1988
- Conklin v. CommissionerUnited States Tax Court · 1988
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