Davis v. Commissioner
United States Tax Court
A donation by petitioner to a foundation organized for charitable purposes, held, deductible for gift tax purposes under section 1004 (a) (2) (B), Internal Revenue Code of 1939.
1Opinion of the Court
OPINION.
BRUce, Judge:
The deficiency here arises upon respondent’s dis-allowance of the deduction for gift tax purposes of the conveyance in trust of approximately $250,000 in securities for the benefit of a charitable foundation as not allowable under section 1004 (a) (2) (B),Internal Revenue Code of 1939.1 This action has been taken upon the ground that respondent has ruled the foundation as not tax exempt under section 101 (6), Internal Revenue Code of 1939, and has also ruled as not exempt under that section KWA which was the recipient of certain payments by the foundation under the terms…
2Cases cited5 opinions
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Huntington Nat'l Bank v. CommissionerUnited States Tax Court · 1949
- Slee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Girard Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1941
- Old Colony Trust Co. v. WelchDistrict Court, D. Massachusetts · 1938
3Cited by4 opinions
- Haswell v. United StatesUnited States Court of Claims · 1974
- Carson v. CommissionerUnited States Tax Court · 1978
- Carson v. CommissionerUnited States Tax Court · 1978
- Davis v. CommissionerUnited States Tax Court · 1954