Pescosolido v. Commissioner
United States Tax Court
P, controlling shareholder of L, donated "sec. 306 stock" of L to two educational institutions. Held: P did not establish that the donations were "not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income tax," under sec. 306(b)(4), I.R.C. 1954. P's contributions deductions are limited to his cost basis of the stock under sec. 170(e)(1)(A).
1Opinion of the Court
Carl A. Pescosolido, Sr., and Virginia L. Pescosolido, Petitioners v. Commissioner of Internal Revenue, Respondent
Pescosolido v. Commissioner
Docket No. 44927-86
United States Tax Court
91 T.C. 52; 1988 U.S. Tax Ct. LEXIS 92; 91 T.C. No. 6;
July 18, 1988; As amended July 26, 1988 July 18, 1988, Filed
Decision will be entered under Rule 155.
P, controlling shareholder of L, donated "sec. 306 stock" of L to two educational institutions. Held: P did not establish that the donations were "not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income tax," under sec.…
2Cases cited8 opinions
- United States v. DavisSupreme Court of the United States · 1970
- Northern Trust Co. v. CommissionerUnited States Tax Court · 1986
- Roebling v. CommissionerUnited States Tax Court · 1981
- Eugene W. And Marie P. Fireoved, in Nos. 71-1565 v. United States of America, in Nos. 71-1566, 71-1567Court of Appeals for the Third Circuit · 1972
- Bialo v. CommissionerUnited States Tax Court · 1987
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