Snyder v. Commissioner
United States Tax Court
Petitioner paid $ 25,000 to Einar Erickson, a geologist, and deducted that payment as "exploration expense" under sec. 617, I.R.C. 1954. Erickson caused certain unpatented lode mining claims to be recorded on behalf of petitioner.
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Petitioner paid $ 25,000 to Einar Erickson, a geologist, and deducted that payment as "exploration expense" under sec. 617, I.R.C. 1954. Erickson caused certain unpatented lode mining claims to be recorded on behalf of petitioner. A year later, petitioner donated one of the claims to a charity, claiming a contribution deduction of $ 250,000. Held: 1. The payment made to Erickson was primarily for anticipated tax benefits and is not deductible. 2. Petitioner is not entitled to a charitable contribution deduction. 3. Petitioner is liable for additions to tax under sec. 6653(a) and additional…
1Opinion of the Court
COHEN, Judge:
Respondent determined deficiencies of $12,855 and $28,482.51 in petitioner’s Federal income taxes for 1978 and 1979, respectively, and additions to tax under section 6653(a)1 of $642.75 and $1,424.13, respectively, for those years. By amendment to the answer, respondent seeks additional interest under section 6621(d) on the ground that the deficiency for the year 1979 is attributable to a valuation overstatement within the meaning of section 6659(c).
The deficiency for 1978 arose out of respondent’s disal-lowance of a deduction claimed under section 617 for a payment to Einar…
2Cases cited32 opinions
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