Carson v. Commissioner
United States Tax Court
Petitioners expended directly or contributed to campaign committees substantial amounts of money on behalf of candidates seeking public office during the years 1967, 1968, 1970, and 1971. Held, such expenditures do not constitute transfers taxable as gifts.
1ConcurrenceTannenwald, J.
However, I would eschew the various arguments related to political support in order to attempt to achieve social or economic objectives of a taxpayer and protection and advancement of the taxpayer’s property interests (see Stern v. United States, 436 F.2d 1327, 1330 (5th Cir. 1971)) or relating to inferences to be drawn from the legislative history of the estate and gift taxes. Rather, I would rest my position on the fact that, absent a familial or other personal relationship between a candidate and his benefactor, campaign activities of political candidates (with which political…
2Cases cited7 opinions
- Reisman v. CaplinSupreme Court of the United States · 1964
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Carey v. CommissionerUnited States Tax Court · 1971
- James B. Carey and Margaret Carey v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1972
- Nichols v. CommissionerUnited States Tax Court · 1973
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