Wardwell v. Commissioner
United States Tax Court
Marjorie M. Wardwell paid a church-operated old peoples' home $ 7,500 as a room endowment. Held, the payment was made in consideration of her being granted residence in the home and the right to live there by paying less monthly charges than residents who were not room endowers, and, therefore, the payment was not a "gift or contribution" and not deductible under section 170, I.R.C. 1954.
1Opinion of the Court
Mulroney, Judge:
The respondent determined a deficiency in the income tax of decedents, O. J. and Marjorie M. Wardwell, for the year 1956 in the amount of $661.34.
The question is whether a $7,500 payment by Marjorie M. Wardwell to Friendship Haven, Inc., was deductible as a charitable contribution under section 170(c) of the Internal Revenue Code of 1954.1
findings of fact.
Some of the facts are stipulated and they are found accordingly.
Friendship Haven, Inc., is a charitable corporation, organized in 1946 not for pecuniary profit under the laws of Iowa. It operates the home known as Friendship…
2Cases cited1 opinion
- Commissioner v. DubersteinSupreme Court of the United States · 1960
3Cited by19 opinions
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Seed v. CommissionerUnited States Tax Court · 1971
- Singer Co. v. United StatesUnited States Court of Claims · 1971
- Estate of Wood v. CommissionerUnited States Tax Court · 1962
- DeJong v. CommissionerUnited States Tax Court · 1961
14 more not listed; retrieve them via the Exa API.