Considine v. Commissioner
United States Tax Court
In 1965, petitioners conveyed certain real estate to Capri Builders, Inc., receiving therefor a note in the amount of $ 250,000 (later reduced to $ 225,000) secured by a deed of trust on the property.
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In 1965, petitioners conveyed certain real estate to Capri Builders, Inc., receiving therefor a note in the amount of $ 250,000 (later reduced to $ 225,000) secured by a deed of trust on the property. In 1966, petitioners delivered a quitclaim deed for a 1/21 interest in the note and deed of trust to Tabor Academy, a charitable organization, and claimed a charitable contribution deduction in the amount of $ 23,809.52 (2/21 of $ 250,000) on their income tax return for 1966. In 1968, a judgment was taken against petitioner which was settled for $ 400,000. Petitioners assigned the $ 250,000 note…
1Opinion of the Court
Drennen, Judge:
Respondent determined a deficiency in petitioners’ income tax for 1970 in the amount of $27,166. In making this determination, respondent concurrently disallowed petitioners’ claim for refund for 1970 in the amount of $3,685.
Due to concessions by both parties,1 the only issue for our decision is whether petitioners are entitled to any charitable contribution deduction for the payment in 1970 of $20,000 to Tabor Academy.2
FINDINGS OF FACT
Some of the facts were stipulated and they are so found. The stipulation of facts together with the exhibits attached thereto are incorporated…
2Cases cited17 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
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3Cited by16 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Primo Pants Co. v. CommissionerUnited States Tax Court · 1982
- Anderson v. CommissionerUnited States Tax Court · 1984
- Veterans of Foreign Wars, Dep't of Michigan v. CommissionerUnited States Tax Court · 1987
- Kim v. Comm'rUnited States Tax Court · 2007
11 more not listed; retrieve them via the Exa API.