Gagne v. Commissioner
United States Tax Court
1. Charitable contribution made subject to donee's compliance with certain conditions held deductible in year donee agreed to so comply and accepted the contribution. 2. The tax for the year 1943 imposed by Chapter 1 of the Internal Revenue Code includes the increase in tax for that year occasioned by section 6 of the Current Tax Payment Act of 1943 for the purpose of computing the 90 per cent victory tax limitation prescribed by section 456 of the Code.
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1. Charitable contribution made subject to donee's compliance with certain conditions held deductible in year donee agreed to so comply and accepted the contribution. 2. The tax for the year 1943 imposed by Chapter 1 of the Internal Revenue Code includes the increase in tax for that year occasioned by section 6 of the Current Tax Payment Act of 1943 for the purpose of computing the 90 per cent victory tax limitation prescribed by section 456 of the Code. Guest v. Commissioner, 175 Fed. (2d) 868, followed.
1Opinion of the Court
Linwood A. Gagne, Petitioner, v. Commissioner of Internal Revenue, Respondent
Gagne v. Commissioner
Docket No. 17193
United States Tax Court
16 T.C. 498; 1951 U.S. Tax Ct. LEXIS 259;
February 28, 1951, Promulgated
Decision will be entered under Rule 50.
1. Charitable contribution made subject to donee's compliance with certain conditions held deductible in year donee agreed to so comply and accepted the contribution.
2. The tax for the year 1943 imposed by Chapter 1 of the Internal Revenue Code includes the increase in tax for that year occasioned by section 6 of the Current Tax Payment Act of 1943…
2Cases cited4 opinions
- Spiegel v. CommissionerUnited States Tax Court · 1949
- Marx v. CommissionerUnited States Tax Court · 1949
- Guest v. CommissionerUnited States Tax Court · 1948
- Gagne v. CommissionerUnited States Tax Court · 1951