Appleby v. Commissioner
United States Tax Court
Held, petitioners' contributions to a trust of which a college was sole beneficiary did not qualify for the additional 10-percent deduction under the special rule of sec. 170(b)(1)(A) of the 1954 Code because they were not made to the college, as required by the statute.
1Opinion of the Court
MulroNey, Judge:
Respondent determined deficiencies in petitioners’ income tax for the years 1963 and 1964 in the respective amounts of $1,002.64 and $555.13.
The only assignment of error in the petition is that respondent erred in determining that their contributions to a trust did not qualify for the additional deduction provided in section 170 (b) (1) (A), I.R.C. 1954.1
BINDINGS OK FACT AND OPINION
All of the facts have been stipulated and they are found accordingly.
Petitioners are husband and wife, who reside in Bellevue, Ohio. They filed their joint income tax returns for 1963 and 1964 with…
2Cited by8 opinions
- Chapman v. Commissioner of RevenueSupreme Court of Minnesota · 2002
- Allen v. CommissionerUnited States Tax Court · 1968
- Rockefeller v. CommissionerUnited States Tax Court · 1981
- James v. CommissionerUnited States Tax Court · 1974
- Appleby v. CommissionerUnited States Tax Court · 1967
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