Estate of Carroll v. Commissioner
United States Tax Court
Held, that expenditures made by the decedent, Philip A. Carroll, for repairing and refurbishing a chapel located on an ancestral estate owned by him, which for more than 240 years has been used exclusively by the Roman Catholic Church as a parish church for the surrounding community, are deductible as charitable contributions under section 23(o)(2) of the 1939 Code and section 170(c) of the 1954 Code.
1Opinion of the Court
Pierce, Judge:
The respondent determined deficiencies in income taxes for the calendar years 1953 and 1954, in the amounts of $12,352.94 and $4,168.02, respectively.
The sole issue for decision is whether certain expenditures made by the decedent, Philip A. Carroll, for repairing, rehabilitating, and redecorating a chapel located on his ancestral estate in Maryland, which for a period of more than 240 years has been used exclusively by the Eoman Catholic Church as a “public oratory” that functions as the parish church of the community, are deductible for income tax purposes as charitable…
2Cases cited3 opinions
- Whitehead v. CommissionerUnited States Tax Court · 1944
- Commissioner of Internal Revenue v. Citizens & Southern Nat. BankCourt of Appeals for the Fifth Circuit · 1945
- Cartan v. CommissionerUnited States Tax Court · 1958
3Cited by13 opinions
- Graham v. CommissionerCourt of Appeals for the Ninth Circuit · 1987
- John Herbert Orr and Elizabeth G. Orr v. United StatesCourt of Appeals for the Fifth Circuit · 1965
- University Hill Foundation v. CommissionerUnited States Tax Court · 1969
- Anne Archbold, by John D. Archbold, of the Estate of Anne Archbold, Deceased v. The United StatesUnited States Court of Claims · 1971
- Rockefeller v. CommissionerUnited States Tax Court · 1981
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