Legal Opinion

Appleby v. Commissioner

United States Tax Court

Decided June 16, 1967No. Docket No. 1948-66Published

Held, petitioners' contributions to a trust of which a college was sole beneficiary did not qualify for the additional 10-percent deduction under the special rule of sec. 170(b)(1)(A) of the 1954 Code because they were not made to the college, as required by the statute.

1Opinion of the Court

John I. Appleby and Carolyn M. Appleby, Petitioners v. Commissioner of Internal Revenue, Respondent

Appleby v. Commissioner

Docket No. 1948-66

United States Tax Court

48 T.C. 330; 1967 U.S. Tax Ct. LEXIS 90;

June 16, 1967, Filed

Decision will be entered under Rule 50.

Held, petitioners' contributions to a trust of which a college was sole beneficiary did not qualify for the additional 10-percent deduction under the special rule of sec. 170(b)(1)(A) of the 1954 Code because they were not made to the college, as required by the statute.

Arthur W. Moore, for the petitioners.

Frank E. Wrenick, for the…

2Cases cited2 opinions

  1. John Herbert Orr and Elizabeth G. Orr v. United StatesCourt of Appeals for the Fifth Circuit · 1965
  2. Appleby v. CommissionerUnited States Tax Court · 1967

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