Story v. Commissioner
United States Tax Court
Petitioners advanced $ 45,194.68 to a charitable organization in 1955 to build a chapel and received a promissory note from the organization in the amount of the funds advanced. After consulting their tax advisor at the end of each year, petitioners forgave a portion of the principal amount of the note each year by endorsing on the back thereof the amount canceled by gift.
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Petitioners advanced $ 45,194.68 to a charitable organization in 1955 to build a chapel and received a promissory note from the organization in the amount of the funds advanced. After consulting their tax advisor at the end of each year, petitioners forgave a portion of the principal amount of the note each year by endorsing on the back thereof the amount canceled by gift. Held, petitioners did not make a gift of the entire amount advanced in 1955. Held, further, petitioners are entitled to deduct as a charitable contribution, to the extent allowed under section 170, I.R.C. 1954, the amount…
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in petitioners’ income tax for the years 1955,1956,1957, and 1958 in the amounts of $861.39, $1,129.02, $2,212.29, and $2,027.38, respectively.
As a result of concessions by the parties, the only issue remaining for decision is whether petitioners are entitled to deduct as charitable contributions to Soldiers Chapel Corporation (hereinafter referred to as Soldiers Chapel), under section 170 of the 1954 Code, the amount of $6,200 in 1957 and the amount of $6,100 in 1958. Petitioners advanced the sum of $45,194.68 to build a chapel for Soldiers…
2Cases cited2 opinions
- Deal v. CommissionerUnited States Tax Court · 1958
- Andrus v. BurnetCourt of Appeals for the D.C. Circuit · 1931
3Cited by22 opinions
- Christensen v. CommissionerUnited States Tax Court · 1963
- Estate of Kelley v. CommissionerUnited States Tax Court · 1974
- Haygood v. CommissionerUnited States Tax Court · 1964
- Laughinghouse v. Comm'rUnited States Tax Court · 1983
- Davies v. CommissionerUnited States Tax Court · 1963
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