Legal Opinion

Carson v. Commissioner

United States Tax Court

Decided November 22, 1978No. Docket No. 9638-74Published

Petitioners expended directly or contributed to campaign committees substantial amounts of money on behalf of candidates seeking public office during the years 1967, 1968, 1970, and 1971. Held, such expenditures do not constitute transfers taxable as gifts.

1Opinion of the Court

David W. Carson and Marjorie E. Carson, Petitioners v. Commissioner of Internal Revenue, Respondent

Carson v. Commissioner

Docket No. 9638-74

United States Tax Court

71 T.C. 252; 1978 U.S. Tax Ct. LEXIS 23;

November 22, 1978, Filed

Decision will be entered for the petitioner.

Petitioners expended directly or contributed to campaign committees substantial amounts of money on behalf of candidates seeking public office during the years 1967, 1968, 1970, and 1971. Held, such expenditures do not constitute transfers taxable as gifts.

Scott I. Asner, for the petitioners.

George T. Morse III, for the…

Also in this document: Concurrence · Tannenwald; Concurrence · Hall; Dissent · Simpson; Dissent · Chabot.

2Cases cited42 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  3. Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
  4. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  5. Reisman v. CaplinSupreme Court of the United States · 1964

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