Story v. Commissioner
United States Tax Court
Petitioners advanced $ 45,194.68 to a charitable organization in 1955 to build a chapel and received a promissory note from the organization in the amount of the funds advanced. After consulting their tax advisor at the end of each year, petitioners forgave a portion of the principal amount of the note each year by endorsing on the back thereof the amount canceled by gift.
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Petitioners advanced $ 45,194.68 to a charitable organization in 1955 to build a chapel and received a promissory note from the organization in the amount of the funds advanced. After consulting their tax advisor at the end of each year, petitioners forgave a portion of the principal amount of the note each year by endorsing on the back thereof the amount canceled by gift. Held, petitioners did not make a gift of the entire amount advanced in 1955. Held, further, petitioners are entitled to deduct as a charitable contribution, to the extent allowed under section 170, I.R.C. 1954, the amount…
1Opinion of the Court
Nelson Story III and Velma E. Story, Petitioners, v. Commissioner of Internal Revenue, Respondent
Story v. Commissioner
Docket No. 88371
United States Tax Court
38 T.C. 936; 1962 U.S. Tax Ct. LEXIS 71;
September 24, 1962, Filed
Decision will be entered under Rule 50.
Petitioners advanced $ 45,194.68 to a charitable organization in 1955 to build a chapel and received a promissory note from the organization in the amount of the funds advanced. After consulting their tax advisor at the end of each year, petitioners forgave a portion of the principal amount of the note each year by endorsing on the back…
2Cases cited4 opinions
- Deal v. CommissionerUnited States Tax Court · 1958
- Story v. CommissionerUnited States Tax Court · 1962
- Mustard v. United StatesUnited States Court of Claims · 1957
- Andrus v. BurnetCourt of Appeals for the D.C. Circuit · 1931