Tatum v. Commissioner
United States Tax Court
Petitioners owned farmland which they rented to tenants for growing grain and cotton. As rent for the use of the land, the tenants paid petitioners one-third of all grain and one-fourth of all cotton produced.
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Petitioners owned farmland which they rented to tenants for growing grain and cotton. As rent for the use of the land, the tenants paid petitioners one-third of all grain and one-fourth of all cotton produced. In 1961 and 1962 petitioners donated sharecrop rents, in the form of negotiable warehouse receipts and cotton classing cards, to certain charitable organizations qualifying under section 170(c), I.R.C. 1954, and such rents were converted to cash by the charitable donees in the years received. In their income tax returns petitioners claimed and were allowed charitable deductions for the…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined deficiencies in the income taxes of petitioners for the taxable years 1961 and 1962 in the amounts of $954.75 and $1,135.52, respectively. The sole issue for decision is whether petitioners, who gave to certain charitable organizations negotiable warehouse receipts evidencing sharecrop rents, must include in their gross income the amounts received by the donees for the crop shares in the taxable years when they were reduced to money or its equivalent.
All of the facts have been stipulated by the parties. The stipulation of facts, together with the…
2Cases cited8 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- SoRelle v. CommissionerUnited States Tax Court · 1954
- Campbell, Collector of Internal Revenue v. Prothro Et UxCourt of Appeals for the Fifth Circuit · 1954
- Farrier v. CommissionerUnited States Tax Court · 1950
- Estate of Helen Davison, Deceased, First National Bank of Arizona v. United StatesCourt of Appeals for the First Circuit · 1961
3 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- University Hill Foundation v. CommissionerUnited States Tax Court · 1969
- Sheldon v. CommissionerUnited States Tax Court · 1974
- Strong v. CommissionerUnited States Tax Court · 1988
- Applegate v. CommissionerUnited States Tax Court · 1990
- Peeler Realty Co. v. CommissionerUnited States Tax Court · 1973
13 more not listed; retrieve them via the Exa API.