Legal Opinion

Allen v. Commissioner

United States Tax Court

Decided October 4, 1971No. Docket No. 2501-70Published

Taxpayer, in 1965, made a gift of a 5-year rent-free lease of property to a charity. In 1966 and 1967, taxpayer took charitable deductions based on the annual fair rental value of the property. Held: Taxpayer made a single, completed gift in 1965 and was entitled to a charitable deduction in that year equal to the fair market value of the interest conveyed. Taxpayer's annualization of the charitable contribution deduction was not proper in this case.

1Opinion of the Court

John G. Allen and Maxine S. Allen, Petitioners v. Commissioner of Internal Revenue, Respondent

Allen v. Commissioner

Docket No. 2501-70

United States Tax Court

57 T.C. 12; 1971 U.S. Tax Ct. LEXIS 47;

October 4, 1971, Filed

Decision will be entered under Rule 50.

Taxpayer, in 1965, made a gift of a 5-year rent-free lease of property to a charity. In 1966 and 1967, taxpayer took charitable deductions based on the annual fair rental value of the property. Held: Taxpayer made a single, completed gift in 1965 and was entitled to a charitable deduction in that year equal to the fair market value of the…

2Cases cited2 opinions

  1. Passailaigue v. United StatesDistrict Court, M.D. Georgia · 1963
  2. Allen v. CommissionerUnited States Tax Court · 1971

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