Legal Opinion

Lucky Stores v. Commissioner

United States Tax Court

Decided December 19, 1995No. Docket No. 4446-93Published

P made donations of its surplus bread inventory to food banks which qualified as permissible charitable donees under sec. 170(e)(3)(A), I.R.C., and claimed charitable contribution deductions based upon full retail prices for the bread. R determined the fair market value to be approximately 50 percent of full retail prices. Held, fair market value of P's bread contributions redetermined.

1Opinion of the Court

LUCKY STORES, INC., AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Lucky Stores v. Commissioner

Docket No. 4446-93.

United States Tax Court

105 T.C. 420; 1995 U.S. Tax Ct. LEXIS 65; 105 T.C. No. 28;

December 19, 1995, Filed

An appropriate order will be issued directing entry of decision under Rule 155 upon completion of proceedings resolving the remaining issue in this case, and sustaining respondent's hearsay objection.

P made donations of its surplus bread inventory to food banks which qualified as permissible charitable donees under sec. 170(e)(3)(A), I.R.C., and…

2Cases cited5 opinions

  1. Estate of Lang v. CommissionerUnited States Tax Court · 1975
  2. The Estate of Grace E. Lang, Deceased. Richard E. Lang v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  3. Zaentz v. CommissionerUnited States Tax Court · 1979
  4. Jacob J. Cooley v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
  5. Lucky Stores v. CommissionerUnited States Tax Court · 1995

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