Legal Opinion

Smith v. Commissioner

United States Tax Court

Decided July 20, 1981No. Docket Nos. 9667-77, 8798-78Unpublished

Petitioner, a professional writer, wrote a book which was published and copyrighted in 1967. Only 6,000 copies of this book were printed originally. In 1975, petitioner presented the copyright certificate to the directors of a museum. On his 1975 income tax return, petitioner claimed a charitable contribution deduction of $ 30,000 for donation of the copyright interest.

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Petitioner, a professional writer, wrote a book which was published and copyrighted in 1967. Only 6,000 copies of this book were printed originally. In 1975, petitioner presented the copyright certificate to the directors of a museum. On his 1975 income tax return, petitioner claimed a charitable contribution deduction of $ 30,000 for donation of the copyright interest. Due to the limits of section 170(b)(1)(A), I.R.C. 1954, a portion of this deduction was carried over to 1976 under section 170(d)(1), I.R.C. 1954. Various other itemized deductions were claimed for 1974, 1975 and 1976, for…

1Opinion of the Court

ROBERT T. SMITH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; ROBERT T. SMITH and EDNA L. SMITH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

Smith v. Commissioner

Docket Nos. 9667-77, 8798-78

United States Tax Court

T.C. Memo 1981-371; 1981 Tax Ct. Memo LEXIS 372; 42 T.C.M. (CCH) 431; T.C.M. (RIA) 81371;

July 20, 1981

Petitioner, a professional writer, wrote a book which was published and copyrighted in 1967. Only 6,000 copies of this book were printed originally. In 1975, petitioner presented the copyright certificate to the directors of a museum. On his 1975 income…

2Cases cited44 opinions

  1. Miranda v. ArizonaSupreme Court of the United States · 1966
  2. Welch v. HelveringSupreme Court of the United States · 1933
  3. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  4. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  5. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940

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