Legal Opinion

Giordano v. Commissioner

United States Tax Court

Decided January 15, 1975No. Docket Nos. 2287-73, 7202-73, 8177-73PublishedCited by 29 opinions

Rule 121, Tax Court Rules of Practice and Procedure. -- (1) Respondent's motion for summary judgment, insofar as it seeks to sustain his disallowance of certain deductions for payments made by petitioner to an organization which petitioner contends is exempt from tax under a section of the Internal Revenue Code of 1954 which permits contributions to it to be deductible, is denied since there is a genuine issue of material fact with respect to the deductibility of these…

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Rule 121, Tax Court Rules of Practice and Procedure. -- (1) Respondent's motion for summary judgment, insofar as it seeks to sustain his disallowance of certain deductions for payments made by petitioner to an organization which petitioner contends is exempt from tax under a section of the Internal Revenue Code of 1954 which permits contributions to it to be deductible, is denied since there is a genuine issue of material fact with respect to the deductibility of these items. (2) Respondent's motion for summary judgment requesting that his disallowance of a portion of deductions claimed for…

1Opinion of the Court

OPINION

Scott, Judge:

Respondent determined deficiencies in petitioners’ Federal income taxes for the calendar years 1968, 1969, 1970, and 1971 in the amounts of $1,881.45, $887.14, $714.56, and $4,777.42, respectively.

Petitioners John C. Giordano and Nancy J. Giordano filed joint Federal income tax returns for the calendar years 1969, 1970, and 1971, and petitioner John C. Giordano, hereinafter referred to as petitioner, filed an individual Federal income tax return for the calendar year 1968.

Numerous adjustments were made in each of these years in respondent’s notices of deficiency, and among…

2Cases cited5 opinions

  1. Commissioner v. LesterSupreme Court of the United States · 1961
  2. Arthur G. B. Metcalf v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1965
  3. Grummer v. CommissionerUnited States Tax Court · 1966
  4. Thomson v. CommissionerUnited States Tax Court · 1964
  5. Talberth v. CommissionerUnited States Tax Court · 1966

3Cited by29 opinions

  1. Espinoza v. CommissionerUnited States Tax Court · 1982
  2. Abramo v. CommissionerUnited States Tax Court · 1982
  3. H Enters. Int'l v. CommissionerUnited States Tax Court · 1995
  4. Mass v. CommissionerUnited States Tax Court · 1983
  5. Herbert L. Sperling and Janice Sperling v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1984

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