Thomason v. Commissioner
United States Tax Court
Amounts paid for the benefit of, and to provide special advantages for, a designated ward of a charitable organization, held not deductible as charitable contributions.
1Opinion of the Court
OPINION.
Akundell, Judge:
The respondent argues that petitioner is not entitled to deduct as charitable contributions these amounts paid out on behalf of a particular ward of a public charity, as such contributions were for the benefit of a single individual and, hence, constituted private charitable contributions.
The petitioner argues that these expenditures were made “for the use of” a public charity and as such are deductible under section 23 (o) of the Internal Revenue Code.1
We think the respondent correctly denied the deductions. The contributions here in question were paid directly to…
2Cases cited2 opinions
- Russell v. AllenSupreme Court of the United States · 1883
- Bullard v. ChandlerMassachusetts Supreme Judicial Court · 1889
3Cited by30 opinions
- Davis v. United StatesSupreme Court of the United States · 1990
- Tate v. CommissionerUnited States Tax Court · 1973
- Peace v. CommissionerUnited States Tax Court · 1964
- Jacob Oppewal v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1972
- Winn v. CommissionerUnited States Tax Court · 1976
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