Canada v. Commissioner
United States Tax Court
Petitioners seek to deduct as charitable contributions certain transfers of land and money to the Kneadmore Life Community Church (KLCC). The KLCC's members occupied the land as an "intentional community where [they] could pursue common values of living in harmony with nature." The KLCC provided its members, inter alia, with rent-free accommodations and farmland, use of farm equipment and seed, and food grown in community gardens and orchards.
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Petitioners seek to deduct as charitable contributions certain transfers of land and money to the Kneadmore Life Community Church (KLCC). The KLCC's members occupied the land as an "intentional community where [they] could pursue common values of living in harmony with nature." The KLCC provided its members, inter alia, with rent-free accommodations and farmland, use of farm equipment and seed, and food grown in community gardens and orchards. These benefits were not provided as compensation for services performed. Held, petitioners' deductions denied because the KLCC was operated for a…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes:
Petitioner Year Deficiency
$19,105.17 76,473.53 Carter Hawkms Canada (f.k.a. Larry E. Canada-, Jr.) and Katherine N. Canada H-1 M CD CD 0^ CO
1975 67,570.11 Katherine N. Canada
After concessions, the sole issue for decision is whether petitioners are entitled to deduct, as charitable contributions pursuant to section 170,1 amounts attributable to land and money transferred to the Kneadmore Life Community Church (KLCC).
FINDINGS OF FACT
Some of the facts have been stipulated and are found…
2Cases cited19 opinions
- Wisconsin v. YoderSupreme Court of the United States · 1972
- United States v. SeegerSupreme Court of the United States · 1965
- United States v. LeeSupreme Court of the United States · 1982
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- McGahen v. CommissionerUnited States Tax Court · 1981
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3Cited by14 opinions
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