Sheldon v. Commissioner
United States Tax Court
In the fall preceding each year in controversy, petitioners gathered their cotton and had it ginned and placed in a marketing pool operated by Calcot, Ltd., a cooperative of which they were members. The cooperative commingled its members' cotton and expeditiously marketed it according to grade and staple. In January of each year in issue, petitioners invoiced designated bales of cotton to their church, and it received the net proceeds attributable to those bales.
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In the fall preceding each year in controversy, petitioners gathered their cotton and had it ginned and placed in a marketing pool operated by Calcot, Ltd., a cooperative of which they were members. The cooperative commingled its members' cotton and expeditiously marketed it according to grade and staple. In January of each year in issue, petitioners invoiced designated bales of cotton to their church, and it received the net proceeds attributable to those bales. Petitioners claimed and were allowed charitable contribution deductions under sec. 170, I.R.C. 1954, for the amounts received by…
1Opinion of the Court
FeatheRston, Judge:
Respondent determined deficiencies in petitioners’ income tax for 1965 through 1969 as follows:
Year Amount Year Amount
1965_$1, 739.12 1968_$1,945.00
1966 _ 2,434. SO 1969 _ 3, 752. 00
1967 _ 2, 935. 55
The issue is whether petitioners properly excluded from their gross income, as defined in section 61,1.R.C. 1954, amounts received by the Porterville Church of the Nazareno from the marketing of their cotton by a cooperative marketing association. The answer depends on whether petitioners made gifts to the church of bales of cotton as such or the sales proceeds attributable to…
2Cases cited22 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Helvering v. OwensSupreme Court of the United States · 1939
- SoRelle v. CommissionerUnited States Tax Court · 1954
- Commissioner of Internal Revenue v. LindeCourt of Appeals for the Ninth Circuit · 1954
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3Cited by10 opinions
- S. C. Johnson & Son, Inc. v. CommissionerUnited States Tax Court · 1975
- Schniers v. CommissionerUnited States Tax Court · 1977
- Griffith v. CommissionerUnited States Tax Court · 1980
- Morgan Guaranty Trust Co. of New York v. United StatesUnited States Court of Claims · 1978
- Estate of Applestein v. CommissionerUnited States Tax Court · 1983
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