Legal Opinion

Bell v. Commissioner

United States Tax Court

Decided September 5, 1985No. Docket Nos. 16913-83, 26082-84PublishedCited by 22 opinions

Under the facts, it is held: 1. Petitioners were not entitled to certain claimed charitable contributions. 2. Allowable business expenses were determined. 3. Additions under sec. 6653(a), I.R.C. 1954, determined. 4. Award of damages to the United States under sec. 6673 was appropriate. Application of said section in this case was not an unconstitutional infringement of P's First Amendment rights.

1Opinion of the Court

OPINION

Kórner, Judge:

In these consolidated cases, respondent determined deficiencies in income tax and additions to tax against petitioners as follows:

_Additions to tax_

Year Deficiency Sec. 6653(a)(1)1 Sec. 6653(a)(2)

0 1979 $1,883 ^ €©•

0 1980 8,002 o

To be determined 1981 7,867 co 0) CO

0 1982 21,018 o

The issues which the Court must decide are as follows:(1) Whether petitioners are entitled to claimed deductions for the years in issue for charitable contributions, in the respective amounts of $6,027, $25,627, $22,877, and $2,396;(2) Whether petitioners are entitled to a claimed deduction for…

2Cases cited18 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Schenck v. United StatesSupreme Court of the United States · 1919
  3. Bixby v. CommissionerUnited States Tax Court · 1972
  4. Hatfield v. CommissionerUnited States Tax Court · 1977
  5. Abrams v. CommissionerUnited States Tax Court · 1984

13 more not listed; retrieve them via the Exa API.

3Cited by22 opinions

  1. Emmons v. CommissionerUnited States Tax Court · 1989
  2. Wedvik v. CommissionerUnited States Tax Court · 1986
  3. Wiggins v. Comm'rUnited States Tax Court · 1989
  4. Denbow v. CommissionerUnited States Tax Court · 1989
  5. Dew v. CommissionerUnited States Tax Court · 1988

17 more not listed; retrieve them via the Exa API.

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