Carson v. Commissioner
United States Tax Court
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.
1DissentChabot, J.
The majority conclude that the transfers here at issue are not subject to tax under section 2501(a)(1),1 even though the language of sections 2511(a)2 and 2512(b)3 literally encompasses these transfers.
The reasons presented in the majority opinion—(1) Have the effect of repealing several provisions of the Internal Revenue Code;(2) Are warranted by neither the Code, the legislative history, nor prior Court rulings; and(3) Are likely to create unwarranted confusion for the future. Accordingly, I respectfully dissent.
The| majority opinion (p.258 supra) recapitulates “the key facts before us in…
2Cases cited24 opinions
- Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Ould v. Washington Hospital for FoundlingsSupreme Court of the United States · 1877
- Merrill v. FahsSupreme Court of the United States · 1945
- Leubuscher v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
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