Rosen v. Commissioner
United States Tax Court
T made an unrestricted gift of property to charity A in 1972, and claimed a charitable contribution deduction in respect thereof on T's 1972 income tax return which was apparently allowed. In 1973, A returned the property to T without consideration, although under no legal or other obligation to do so.
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T made an unrestricted gift of property to charity A in 1972, and claimed a charitable contribution deduction in respect thereof on T's 1972 income tax return which was apparently allowed. In 1973, A returned the property to T without consideration, although under no legal or other obligation to do so. Later that year, T made an unrestricted gift of the same property to charity B, and claimed a second charitable contribution deduction in respect of that gift on T's 1973 income tax return which was allowed. In 1974, B returned the property to T without consideration, although under no legal or…
1Opinion of the Court
Sidney W. Rosen and Lorraine S. Rosen, Petitioners v. Commissioner of Internal Revenue, Respondent
Rosen v. Commissioner
Docket No. 5590-77
United States Tax Court
71 T.C. 226; 1978 U.S. Tax Ct. LEXIS 25;
November 21, 1978, Filed
Decision will be entered under Rule 155.
T made an unrestricted gift of property to charity A in 1972, and claimed a charitable contribution deduction in respect thereof on T's 1972 income tax return which was apparently allowed. In 1973, A returned the property to T without consideration, although under no legal or other obligation to do so. Later that year, T made an…
2Cases cited26 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- Alice Phelan Sullivan Corporation, a California Corporation v. The United StatesUnited States Court of Claims · 1967
- Nash v. United StatesSupreme Court of the United States · 1970
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