Osborne v. Commissioner
United States Tax Court
Under local law, the City of Colorado Springs was obligated to provide for the safe discharge of waters within Shook's Run, a natural drainage system which ran through petitioner's property. Petitioner constructed and installed a concrete twin box culvert and related drainage facilities in Shook's Run and transferred them to the city. He also granted easements to the city over the drainage system to facilitate its repair and maintenance.
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Under local law, the City of Colorado Springs was obligated to provide for the safe discharge of waters within Shook's Run, a natural drainage system which ran through petitioner's property. Petitioner constructed and installed a concrete twin box culvert and related drainage facilities in Shook's Run and transferred them to the city. He also granted easements to the city over the drainage system to facilitate its repair and maintenance. Petitioner claimed a charitable contribution deduction under sec. 170, I.R.C. 1954, for his expenditures incurred in constructing and installing the…
1Opinion of the Court
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $14,307 in petitioners’ Federal income tax for 1981. The issue for decision is: Whether petitioners are entitled to a deduction for a charitable contribution under section 1701 for the installation and transfer of drainage facilities and easements to the City of Colorado Springs.
FINDINGS OF FACT
Petitioners Robert P. Osborne and Carol A. Osborne, husband and wife, resided in Colorado Springs, Colorado, at the time the petition was filed. Petitioners filed a joint Federal income tax return for the taxable year 1981 with the…
2Cases cited11 opinions
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Robert C. Stubbs and Mary Ann Stubbs, Husband and Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1970
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Sutton v. CommissionerUnited States Tax Court · 1971
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3Cited by6 opinions
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- DuVal v. CommissionerUnited States Tax Court · 1994
- Estate of Armstrong v. Comm'rUnited States Tax Court · 2002
- Estate of Frank Armstrong, Jr., Frank Armstrong III v. CommissionerUnited States Tax Court · 2002
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