Rockefeller v. Commissioner
United States Tax Court
Held, unreimbursed expenses incurred in rendering services to qualified charitable organizations qualify for the unlimited charitable contribution deduction allowed under secs. 170(b)(1)(C) and 170(g), I.R.C. 1954, in effect for the years 1969, 1970, and 1971.
1Opinion of the Court
OPINION
Drennen, Judge:
Respondent determined deficiencies in income tax of the petitioners as follows:
Docket No. Year Deficiency
9356-77 . 1970 $34,266
1971 57,295
9357-77 . 1969 130,081
1970 125,216
1971 234,403
The cases were consolidated for briefing and opinion. The only issue for decision is whether unreimbursed expenses incurred by the taxpayers in rendering services to qualifying charities, which are conceded by respondent to qualify as charitable contributions, qualify for the so-called unlimited charitable contribution deduction allowed under sections 170(b)(1)(C) and 170(g), I.R.C. 1954,1…
2Cases cited12 opinions
- Danz v. CommissionerUnited States Tax Court · 1952
- The John Danz Charitable Trust v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- John Herbert Orr and Elizabeth G. Orr v. United StatesCourt of Appeals for the Fifth Circuit · 1965
- Whitehead v. CommissionerUnited States Tax Court · 1944
- Commissioner of Internal Revenue v. Citizens & Southern Nat. BankCourt of Appeals for the Fifth Circuit · 1945
7 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Chapman v. Commissioner of RevenueSupreme Court of Minnesota · 2002
- Van Dusen v. CommissionerUnited States Tax Court · 2011
- Eldon D. Brinley and Mary Alice Brinley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
- Bell v. Comm'rUnited States Tax Court · 2011
- Chapman v. Commissioner of RevenueSupreme Court of Minnesota · 2002
4 more not listed; retrieve them via the Exa API.