Legal Opinion
William Stephen Allen and Jane E. Allen, His Wife v. United States
Court of Appeals for the Ninth Circuit
Decided September 20, 1976No. 74-2506PublishedCited by 26 opinions
1Opinion of the Court
ALFRED T. GOODWIN, Circuit Judge:
The district court granted a refund after finding the taxpayers entitled to a charitable deduction under Internal Revenue Code of 1954 § 170(c)(1) for the market value of 9.2 acres of redwoods deeded to the City of Mill Valley, California. The government appeals.
In 1963, taxpayers bought for investment purposes 22 acres of land zoned for one-acre residential lots. Mill Valley had an ordinance allowing “cluster zoning” that would permit a subdivider to divide a tract into half-acre lots, notwithstanding the one-acre-lot-size rule, provided that equivalent land…
2Cases cited6 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Robert C. Stubbs and Mary Ann Stubbs, Husband and Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1970
- United States v. Transamerica Corporation, Transamerica Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1968
1 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Foster v. Comm'rUnited States Tax Court · 1983
- Graham v. CommissionerCourt of Appeals for the Ninth Circuit · 1987
- Impulsora Del Territoria Sur, S.A. v. Cecchini (In Re Cecchini)United States Bankruptcy Appellate Panel for the Ninth Circuit · 1984
- Parkside, Inc. And Beaconcrest, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1977
21 more not listed; retrieve them via the Exa API.