Goldstein v. Commissioner
United States Tax Court
On Dec. 27, 1980, petitioners, husband and wife, purchased from an art dealer warehouse receipts representing a large quantity of posters. Petitioners paid for the posters, as represented by the warehouse receipts, with a small cash payment and four recourse promissory notes.
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On Dec. 27, 1980, petitioners, husband and wife, purchased from an art dealer warehouse receipts representing a large quantity of posters. Petitioners paid for the posters, as represented by the warehouse receipts, with a small cash payment and four recourse promissory notes. Petitioners, through the art dealer, petitioners' attorney-in-fact, transferred the warehouse receipts to a charitable organization on Dec. 31, 1980. A year later, the charitable organization resold the receipts to the art dealer with whom petitioners had originally dealt. Held, Petitioners made a charitable contribution…
1Opinion of the Court
HAMBLEN, Judge:
The ‘ Commissioner determined a deficiency in Federal income tax for petitioners’ taxable year ended December 31, 1980, in the amount of $4,943, and an addition to tax for negligence pursuant to section 6653(a)1 in the amount of $247. The issues this Court must decide are (1) whether petitioners made a charitable contribution to Temple Sinai during their 1980 taxable year and, if so, (2) what is the fair market value of the contribution.2
FINDINGS OF FACT
Some of the facts of this case have been stipulated and are so found. Petitioners are husband and wife and resided at…
2Cases cited20 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Neely v. CommissionerUnited States Tax Court · 1985
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Chiu v. CommissionerUnited States Tax Court · 1985
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3Cited by37 opinions
- Follender v. CommissionerUnited States Tax Court · 1987
- Schulman v. CommissionerUnited States Tax Court · 1989
- Cohen v. CommissionerUnited States Tax Court · 1989
- Estate of Davenport v. CommissionerCourt of Appeals for the Tenth Circuit · 1999
- Standley v. CommissionerUnited States Tax Court · 1992
32 more not listed; retrieve them via the Exa API.