Tate v. Commissioner
United States Tax Court
Held, petitioner is not entitled to deduct as a charitable contribution under sec. 170, I.R.C. 1954, the expenses which she incurred in 1967 in sending her minor son to Europe; such expenses were not "incident to the rendition of services to an organization contributions to which are deductible" within the meaning of sec. 1.170-2(a)(2), Income Tax Regs.
1Opinion of the Court
Featherston, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for 1967 in the amount of $216.99. The only issue presented for decision is whether petitioner may deduct as a charitable contribution under section 170 1 certain expenses incurred in connection with her minor son’s visit to Europe.
FINDINGS OF FACT
Grey B. (Miller) Tate (hereinafter referred to as petitioner) filed her Federal income tax return for 1967 with the district director of internal revenue, Buffalo, N.Y. Between the time of filing her 1967 return and the filing of the petition in this case, she…
2Cases cited7 opinions
- Seed v. CommissionerUnited States Tax Court · 1971
- John Herbert Orr and Elizabeth G. Orr v. United StatesCourt of Appeals for the Fifth Circuit · 1965
- Murphy v. CommissionerUnited States Tax Court · 1970
- Saltzman v. CommissionerUnited States Tax Court · 1970
- Thomason v. CommissionerUnited States Tax Court · 1943
2 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Stark v. CommissionerUnited States Tax Court · 1986
- Kurkjian v. CommissionerUnited States Tax Court · 1976
- Smith v. Comm'rUnited States Tax Court · 1973
- Constancio Babilonia and Cleo Babilonia v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
22 more not listed; retrieve them via the Exa API.