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.
1Opinion of the Court
Wilbur, Judge:
Respondent determined the following deficiencies in, and additions to, the Federal gift taxes of petitioners:
Taxable period Petitioner ended Additions to tax Deficiency under sec. 6651(a)1
David W. Carson. 12/31/67 $314.92
12/31/68 821.45
12/31/70 1,088.24
3/31/71 2,606.32
6/30/71 974.11
9/30/71 338.36
12/31/71 93.75
Marjorie E. Carson. 12/31/67 $314.92 $78.73
205.36 12/31/68 821.45
12/31/70 1,088.24
3/31/71 2,606.32
6/30/71 974.11
9/30/71 338.36
12/31/71 93.75
The sole issue we must decide in this case is whether expenditures made by petitioners to finance the election campaigns of various…
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
9 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Estate of Sachs v. CommissionerUnited States Tax Court · 1987
- United States v. William J. ScottCourt of Appeals for the Seventh Circuit · 1982
- Northern Trust Co. v. CommissionerUnited States Tax Court · 1986
- Jacob Abdalla and Mary T. Abdalla v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
- Exxon Corp. v. CommissionerUnited States Tax Court · 1994
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