Legal Opinion

Cooley v. Commissioner

United States Tax Court

Decided November 6, 1959No. Docket No. 68893Published

In 1952, petitioner purchased certain automobiles from General Motors subject to the specific condition that he donate them to the United Jewish Appeal. Held, that inasmuch as these automobiles were never available for resale by petitioner, his charitable deduction should be limited to the amount he paid for them. Sec. 23(o), I.R.C. 1939.

1Opinion of the Court

Jacob J. Cooley, Petitioner, v. Commissioner of Internal Revenue, Respondent

Cooley v. Commissioner

Docket No. 68893

United States Tax Court

1959 U.S. Tax Ct. LEXIS 46; 33 T.C. 223;

November 6, 1959, Filed

Decision will be entered for the respondent.

In 1952, petitioner purchased certain automobiles from General Motors subject to the specific condition that he donate them to the United Jewish Appeal. Held, that inasmuch as these automobiles were never available for resale by petitioner, his charitable deduction should be limited to the amount he paid for them. Sec. 23(o), I.R.C. 1939.

T. Holmes…

2Cases cited1 opinion

  1. Cooley v. CommissionerUnited States Tax Court · 1959

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