David W. Carson and Marjorie E. Carson v. Commissioner of Internal Revenue

McWILLIAMS, Circuit Judge.

This is an appeal pursuant to I.R.C. § 7482 1 from a decision of the United States Tax Court. Carson, the taxpayer, 2 made campaign contributions totaling $209,472.25 during 1967, 1968, 1970, and 1971. The taxpayer filed Federal Gift Tax returns for those periods but didn’t report any of his political contributions. After reviewing such returns, the Commissioner mailed a statutory notice of deficiency to the taxpayer. The taxpayer then brought an action for redetermination in the Tax Court. The Tax Court, with thirteen of its sixteen judges concurring, held that the…