Legal Opinion

Citizens & Southern National Bank of South Carolina v. United States

District Court, W.D. South Carolina

Decided July 22, 1965No. Civ. A. 4259PublishedCited by 22 opinions

1Opinion of the Court

HEMPHILL, District Judge.

In 1959 plaintiff Bank made «contribu_ tions» to the South Carolina Highway Department totalling $27,984.50, and itemized and deducted this amount on its tax return, claiming as charitable deductions under the provisions of 26 U.S.C. § 170(c) (1). 1 The composite consisted of 25,200 square feet of land of $19,000 value, 3400 square feet of $7,000 value and a cash payment of $1984.50 to pay for land belonging to a third party which the Highway Department had to condemn in order to build a road.

The deduction(s) were claimed in conjunction with the construction of a road…

2Cases cited4 opinions

  1. Commissioner of Internal Rev. v. Laguna Land & W. Co.Court of Appeals for the Ninth Circuit · 1941
  2. Chicago & NWR Co. v. Commissioner of Internal Rev.Court of Appeals for the Seventh Circuit · 1940
  3. Allis-Chalmers Manufacturing Co. v. United StatesDistrict Court, E.D. Wisconsin · 1961
  4. Woodside Mills v. United StatesDistrict Court, W.D. South Carolina · 1958

3Cited by22 opinions

  1. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  2. United States v. Transamerica Corporation, Transamerica Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1968
  3. Seed v. CommissionerUnited States Tax Court · 1971
  4. Sutton v. CommissionerUnited States Tax Court · 1971
  5. Singer Co. v. United StatesUnited States Court of Claims · 1971

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