Legal Opinion
Crosby Valve & Gage Company (Formerly Crosby Steam Gage & Valve Company) v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided June 21, 1967No. 6872_1PublishedCited by 35 opinions
1Opinion of the Court
COFFIN, Circuit Judge.
Is a business corporation, wholly owned by a charitable foundation, entitled to a charitable deduction for property (in this case equity in bonds) turned over without consideration to its parent? This is the issue posed by this petition to review a decision of the Tax Court.
The Tax Court held that the transfers to the foundation were not deductible. It placed primary emphasis on its syllogism that (1) “charitable contribution” is synonymous with “gift”; (2) a gift proceeds from a “detached and disinterested generosity”; and (3) since the transfers in this case were the…
2Cases cited9 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Robertson v. United StatesSupreme Court of the United States · 1952
- Channing v. United StatesDistrict Court, D. Massachusetts · 1933
4 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Graham v. CommissionerCourt of Appeals for the Ninth Circuit · 1987
- Singer Co. v. United StatesUnited States Court of Claims · 1971
- Sears, Roebuck and Co. And Affiliated Corporations, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1992
- Marquis v. CommissionerUnited States Tax Court · 1968
30 more not listed; retrieve them via the Exa API.