Connelly v. Commissioner
United States Tax Court
1. In each of the taxable years the petitioner made a contribution to a county fair association which was required by its lease from the county to hold an agricultural fair each year. The Commonwealth of Pennsylvania appropriated money for the support of the association.
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1. In each of the taxable years the petitioner made a contribution to a county fair association which was required by its lease from the county to hold an agricultural fair each year. The Commonwealth of Pennsylvania appropriated money for the support of the association. Held, that the contributions are legal deductions from gross income under section 23 (o), I. R. C. 2. In 1941 the petitioner paid attorneys' fees in connection with litigation involving a deficiency in income tax for 1934. Held, that the amount is a legal deduction from gross income. Howard E. Cammack, 5. T. C. 467, followed.
1Opinion of the Court
OPINION.
Smiti-i, Judge-.
The first question presented is whether the contributions made by the petitioner to the McKean County Fair Association in 1940 and 1941 are legal deductions from gross income under section 23 (o) of the Internal Kevenue Code. That section provides in material part as follows:(o) Chamtable and Other Contributions. — In the case of an individual, contributions or gifts payment of which is made within the taxable year to or for the use of:
* * * * * * *(2) A corporation, trust, or community chest, fund, or foundation, created or organized in the United States or in any…
2Cases cited3 opinions
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Cammack v. CommissionerUnited States Tax Court · 1945
- McKenna v. CommissionerUnited States Tax Court · 1945
3Cited by15 opinions
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- Commissioner of Internal Revenue v. Michael Shapiro and Rae ShapiroCourt of Appeals for the Seventh Circuit · 1960
- Sergievsky v. McNamaraDistrict Court, S.D. New York · 1955
- Heide v. CommissionerUnited States Tax Court · 1947
- Hopkins v. CommissionerUnited States Tax Court · 1958
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