Jacob J. Cooley v. Commissioner of Internal Revenue

In January 1952 the taxpayer purchased from General Motors Corporation thirteen Chevrolet automobiles on the express condition that he would donate them to the United Jewish Appeal for export to the State of Israel for use by disabled veterans. Their cost to him was $17,581“.72 but their fair market value at retail, if he had been privileged to sell them, was $24,700. He claimed the latter sum as a charitable deduction under Section 23 (o) of the Internal Revenue Code of 1939, 26 U.S.C.A. The Tax Court limited this deduction to what he paid for the automobiles. This produced the deficiency in…