Legal Opinion

885 Inv. Co. v. Commissioner

United States Tax Court

Decided August 16, 1990No. Docket Nos. 3547-87, 4560-87Published

In 1979 and 1981, 885, a limited partnership, donated parcels of land to the city of Sacramento for use as a scenic corridor and claimed charitable contribution deductions for such transfers. In 1983, the city conveyed the donated parcels back to 885. Held: 1. No charitable contribution deduction is allowable for the 1979 and 1981 conveyances because such conveyances were subject to a condition, the occurrence of which was not so remote as to be negligible.

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In 1979 and 1981, 885, a limited partnership, donated parcels of land to the city of Sacramento for use as a scenic corridor and claimed charitable contribution deductions for such transfers. In 1983, the city conveyed the donated parcels back to 885. Held: 1. No charitable contribution deduction is allowable for the 1979 and 1981 conveyances because such conveyances were subject to a condition, the occurrence of which was not so remote as to be negligible. Sec. 1.170A-1(e), Income Tax Regs. Therefore, the individual petitioners, partners in 885, are not entitled to deduct as a charitable…

1Opinion of the Court

885 Investment Co., Enlow Ose, Tax Matters Partner, Petitioners v. Commissioner of Internal Revenue, Respondent; Richard D. and M. Elnora Bradish, Edward A. and Karen Y. Christenson, Robert R. and Nancy J. Laddish, and Enlow and Melena Ose, Petitioners v. Commissioner of Internal Revenue, Respondent

885 Inv. Co. v. Commissioner

Docket Nos. 3547-87, 4560-87

United States Tax Court

95 T.C. 156; 1990 U.S. Tax Ct. LEXIS 76; 95 T.C. No. 12;

August 16, 1990, Filed

Decisions will be entered under Rule 155.

In 1979 and 1981, 885, a limited partnership, donated parcels of land to the city of Sacramento for…

2Cases cited35 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Dobson v. CommissionerSupreme Court of the United States · 1944
  3. Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
  4. Mitchell v. United StatesSupreme Court of the United States · 1925
  5. Maxwell v. CommissionerUnited States Tax Court · 1986

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