Goss v. Commissioner
United States Tax Court
1. Held, taxpayer is entitled to a deduction under sec. 170, I.R.C. 1954, for his donation of two essays of his own creation to a qualified charity; the donation of the essays constituted a contribution of property, and not of services.
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1. Held, taxpayer is entitled to a deduction under sec. 170, I.R.C. 1954, for his donation of two essays of his own creation to a qualified charity; the donation of the essays constituted a contribution of property, and not of services. Held, further, the essays had a fair market value of $ 500. 2. Held, the Commissioner properly disallowed deductions for alleged business travel expenditures because taxpayer did not comply with all the substantiation requirements of sec. 274(d), I.R.C. 1954.
1Opinion of the Court
■Wiles, Judge:
Respondent has determined a deficiency in petitioners’ income tax of $1,483.27 for the taxable year 1967. The issues for decision are:(1) Whether petitioners are entitled to a charitable deduction for petitioners’ donation of two essays to a certain charity, and, if so, what the fair market value of those essays was at the time of donation.(2) Whether certain expenses incurred by petitioner for travel in 1967 are deductible as ordinary and necessary business expenses.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Petitioners are Bernard Goss…
2Cases cited4 opinions
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Kaplan v. CommissionerUnited States Tax Court · 1965
- Holmes v. CommissionerUnited States Tax Court · 1971
3Cited by12 opinions
- Grant v. CommissionerUnited States Tax Court · 1985
- Cupler v. CommissionerUnited States Tax Court · 1975
- Tobey v. Comm'rUnited States Tax Court · 1973
- Cupler v. CommissionerUnited States Tax Court · 1975
- Donald Leif Rokke v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1993
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