Legal Opinion

Brinley v. Commissioner

United States Tax Court

Decided June 6, 1984No. Docket No. 28349-81Published

In Brinley v. Commissioner, T.C. Memo. 1983-408, we held that petitioners were not entitled to a charitable contribution deduction under sec. 170, I.R.C. 1954, for amounts paid to a church-designated travel agent for their son's travel to a site of missionary service and for amounts paid directly to their son to sustain him while he served as a missionary for the Church of Jesus Christ of Latter-Day Saints.

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In Brinley v. Commissioner, T.C. Memo. 1983-408, we held that petitioners were not entitled to a charitable contribution deduction under sec. 170, I.R.C. 1954, for amounts paid to a church-designated travel agent for their son's travel to a site of missionary service and for amounts paid directly to their son to sustain him while he served as a missionary for the Church of Jesus Christ of Latter-Day Saints. Petitioners timely filed a motion for reconsideration claiming, inter alia, that the subsequently issued opinion of the Tenth Circuit Court of Appeals in White v. United States, 725 F.2d…

1Opinion of the Court

Eldon D. Brinley and Mary Alice Brinley, Petitioners v. Commissioner of Internal Revenue, Respondent

Brinley v. Commissioner

Docket No. 28349-81

United States Tax Court

82 T.C. 932; 1984 U.S. Tax Ct. LEXIS 59; 82 T.C. No. 70;

June 6, 1984, Filed

In Brinley v. Commissioner, T.C. Memo. 1983-408, we held that petitioners were not entitled to a charitable contribution deduction under sec. 170, I.R.C. 1954, for amounts paid to a church-designated travel agent for their son's travel to a site of missionary service and for amounts paid directly to their son to sustain him while he served as a missionary…

2Cases cited17 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Haft Trust v. CommissionerUnited States Tax Court · 1974
  3. Robin Haft Trust v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1975
  4. Seed v. CommissionerUnited States Tax Court · 1971
  5. Fausner v. CommissionerUnited States Tax Court · 1971

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