Legal Opinion

Holcombe v. Commissioner

United States Tax Court

Decided October 17, 1979No. Docket No. 7398-77PublishedCited by 3 opinions

One of petitioners collected, without payment therefor, used eyeglasses, frames, and lenses from his friends, and patients before and during the years here in issue. This petitioner was well known in the community for his work with indigents and supplied glasses to them without charge. During the years here in issue, petitioner transferred some of the glasses, lenses, and frames he had collected to recognized charitable organizations.

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One of petitioners collected, without payment therefor, used eyeglasses, frames, and lenses from his friends, and patients before and during the years here in issue. This petitioner was well known in the community for his work with indigents and supplied glasses to them without charge. During the years here in issue, petitioner transferred some of the glasses, lenses, and frames he had collected to recognized charitable organizations. Held: The glasses, lenses, and frames collected by petitioner were not gifts to him within the meaning of the income tax laws. Petitioner did acquire ownership…

1Opinion of the Court

Scott, Judge:

Respondent determined deficiencies in petitioners’ income tax for the calendar years 1973,1974, and 1975 in the amounts of $7,419.21, $14,348.01, and $8,250.90, respectively. Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for our decision the following:(1) Whether Eddie C. Holcombe (petitioner) is entitled to deductions for charitable contributions of eyeglasses, lenses, and frames which he collected from various friends and patients and transferred to charitable organizations.(2) If petitioner did make contributions of…

2Cases cited2 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Charles N. Haverly and Ruth L. Haverly v. United StatesCourt of Appeals for the Seventh Circuit · 1975

3Cited by3 opinions

  1. Joseph A. & Dorothy D. Moller v. The United StatesCourt of Appeals for the Federal Circuit · 1983
  2. Holcombe v. CommissionerUnited States Tax Court · 1979
  3. Olken v. CommissionerUnited States Tax Court · 1981

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