Legal Opinion

Seed v. Commissioner

United States Tax Court

Decided November 18, 1971No. Docket Nos. 1845-69, 2300-69PublishedCited by 50 opinions

Petitioners, two married couples who enjoyed playing golf, made payments of $ 4,000 per couple to the People-to-People Sports Committee (Sports Committee), a tax-exempt organization, and incurred additional out-of-pocket expenses in the amount of $ 450 per couple, in connection with a golf tour of Europe sponsored by the Sports Committee.

Read the full summary

Petitioners, two married couples who enjoyed playing golf, made payments of $ 4,000 per couple to the People-to-People Sports Committee (Sports Committee), a tax-exempt organization, and incurred additional out-of-pocket expenses in the amount of $ 450 per couple, in connection with a golf tour of Europe sponsored by the Sports Committee. The Sports Committee arranged a schedule of amateur golf competitions between participants in the golf tour and several European teams, as well as a number of social events at which the tour members could entertain the Europeans with whom they played golf.…

1Opinion of the Court

The Commissioner determined deficiencies in petitioners’ income tax as follows:

Petitioner Tear Deficiency

Harris W. and Nancy C. Seed_ 1966 $2,120. 00

Grant C. and Gretehen W. Ehrlich- 1966 1,318. 98

The sole question presented is whether amounts paid by petitioners in connection with a golf tour of Europe sponsored by the People-to-People Sports Committee are deductible as charitable contributions under section TTO, I.R.C. 1954.

FINDINGS OF FACT

The parties have filed a stipulation of facts which, together with accompanying exhibits, is incorporated herein by this reference.

Harris W. and Nancy C.…

2Cases cited21 opinions

  1. Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
  2. Robert C. Stubbs and Mary Ann Stubbs, Husband and Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1970
  3. United States v. Transamerica Corporation, Transamerica Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1968
  4. Perlmutter v. CommissionerUnited States Tax Court · 1965
  5. Sutton v. CommissionerUnited States Tax Court · 1971

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

3Cited by50 opinions

  1. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  2. Davis v. CommissionerUnited States Tax Court · 1983
  3. Elrod v. CommissionerUnited States Tax Court · 1986
  4. Goldstein v. CommissionerUnited States Tax Court · 1987
  5. Tate v. CommissionerUnited States Tax Court · 1973

45 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