Legal Opinion

Parker v. Commissioner

United States Tax Court

Decided April 2, 1986No. Docket No. 15374-81PublishedCited by 219 opinions

Petitioners paid $ 7,500 to Einar Erickson, a geologist, and deducted that payment as "exploration expense" under sec. 617, I.R.C. 1954. Erickson caused certain unpatented lode mining claims to be recorded on behalf of petitioners.

Read the full summary

Petitioners paid $ 7,500 to Einar Erickson, a geologist, and deducted that payment as "exploration expense" under sec. 617, I.R.C. 1954. Erickson caused certain unpatented lode mining claims to be recorded on behalf of petitioners. A year later, petitioners donated one of the claims to charity, claiming a contribution deduction of $ 125,000. Held: 1. Petitioners failed to prove that the payment made to Erickson was for deductible exploration expenses. 2. Petitioners are not entitled to a charitable contribution deduction for donation of the mining claim. 3. Petitioners are liable for…

1Opinion of the Court

COHEN, Judge:

Respondent determined deficiencies in petitioners’ Federal income taxes as follows:

Year Deficiency Addition to tax sec. 6658(a)1

1977 $2,925 0

1978 18,316 $916

1979 29,458 1,473

The deficiencies resulted from disallowance of a deduction of $7,500, paid to Einar Erickson in 1977, and disallowance of a claimed charitable contribution deduction of $125,000 in 1978, carried over in part to 1979. By amendment to the answer, respondent seeks additional interest under section 6621(d) for 1978 and 1979 on the ground that the claimed contribution was a valuation overstatement within the…

2Cases cited31 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Bixby v. CommissionerUnited States Tax Court · 1972
  3. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  4. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  5. Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980

26 more not listed; retrieve them via the Exa API.

3Cited by219 opinions

  1. Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
  2. Rose v. CommissionerUnited States Tax Court · 1987
  3. Estate of Gilford v. CommissionerUnited States Tax Court · 1987
  4. Symington v. CommissionerUnited States Tax Court · 1986
  5. Taube v. CommissionerUnited States Tax Court · 1987

214 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API