Waller v. Commissioner
United States Tax Court
1. The petitioners were the creators and trustees of the M. & W. Waller Fund and were its sole donors. They donated outright to the Fund securities which had enhanced in value in their hands over the cost basis thereof, and claimed charitable deductions in the amount of the fair market value of such securities.
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1. The petitioners were the creators and trustees of the M. & W. Waller Fund and were its sole donors. They donated outright to the Fund securities which had enhanced in value in their hands over the cost basis thereof, and claimed charitable deductions in the amount of the fair market value of such securities. They also sold to the Fund at their cost basis other securities which had enhanced in value in their hands, receiving payment therefor after the Fund had sold the securities, and claimed deductions of the difference between the fair market value and the amounts received from the Fund.…
1Opinion of the Court
Atkins, Judge :
The respondent determined deficiencies in income tax of petitioners William and Milbrey W. Waller, for the calendar years 1954 and 1955, in the respective amounts of $6,125.59 and $16,256.52, and in income tax of petitioner William Waller for the calendar year 1958 in the amount of $1,942.28.
A number of concessions have been made by the parties. The remaining issues raised by the pleadings are whether the petitioners are entitled to deductions, under section 170(a) of the Internal Revenue Code of 1954, on account of property contributed by them in 1954, 1955, and 1958 to the M.…
2Cases cited21 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Burnet v. LoganSupreme Court of the United States · 1931
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Nicol v. AmesSupreme Court of the United States · 1899
- Shomaker v. CommissionerUnited States Tax Court · 1962
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3Cited by46 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Stark v. CommissionerUnited States Tax Court · 1986
- Skripak v. CommissionerUnited States Tax Court · 1985
- Palmer v. CommissionerUnited States Tax Court · 1974
- Dillin v. CommissionerUnited States Tax Court · 1971
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