Legal Opinion

Londen v. Commissioner

United States Tax Court

Decided October 22, 1965No. Docket Nos. 2142-62, 3089-63PublishedCited by 19 opinions

In December 1958 Jack Winston Londen, president of Green Shield Plan, Inc., told Shoemaker, secretary of Shield, that he wished to donate a portion of the Shield shares represented by an endorsed certificate in Shoemaker's possession to the Jack Winston Londen Foundation, a charitable organization. The donated shares were transferred on Shield's records on January 14, 1959. Londen claimed the value of the shares as a charitable contribution on his 1958 return.

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In December 1958 Jack Winston Londen, president of Green Shield Plan, Inc., told Shoemaker, secretary of Shield, that he wished to donate a portion of the Shield shares represented by an endorsed certificate in Shoemaker's possession to the Jack Winston Londen Foundation, a charitable organization. The donated shares were transferred on Shield's records on January 14, 1959. Londen claimed the value of the shares as a charitable contribution on his 1958 return. In late 1959, Londen told the minister of his church that he planned to donate some Shield shares to the church. The minister told…

1Opinion of the Court

Tannenwald, Judge:1

Respondent determined deficiencies of $1,769.20 and $1,434.70 in petitioners’ income tax for 1958 and 1959, respectively. Initially there were two issues in this case: (1) The deductibility of certain charitable contributions and (2) the correct salvage value of an automobile for purposes of determining depreciation thereon. The respondent has acceded to petitioners’ position on the second issue. As to the first issue, the parties are agreed on the amount of the contributions and the fact that the donees are organizations referred to in section 170 of the 1954 Code. They…

2Cases cited12 opinions

  1. Spiegel v. CommissionerUnited States Tax Court · 1949
  2. Richardson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
  3. Christensen v. CommissionerUnited States Tax Court · 1963
  4. Tracy v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1934
  5. Jules Samann v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963

7 more not listed; retrieve them via the Exa API.

3Cited by19 opinions

  1. Rauenhorst v. Comm'rUnited States Tax Court · 2002
  2. Skripak v. CommissionerUnited States Tax Court · 1985
  3. Guest v. CommissionerUnited States Tax Court · 1981
  4. Ferguson v. CommissionerUnited States Tax Court · 1997
  5. Morrison v. CommissionerUnited States Tax Court · 1987

14 more not listed; retrieve them via the Exa API.

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