Chapman v. Commissioner
United States Tax Court
Petitioners made a contribution to the Missionary Dentist, Inc. (a.k.a. Worldwide Dental Health Service). Held, the contribution does not qualify for the additional 10-percent allowance for charitable contributions under sec. 170(b)(1)(A), I.R.C. 1954. Held, further, petitioners have not met their burden of proving that an expenditure for a garden party was motivated primarily by business rather than personal consideration and therefore such expense is nondeductible under…
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Petitioners made a contribution to the Missionary Dentist, Inc. (a.k.a. Worldwide Dental Health Service). Held, the contribution does not qualify for the additional 10-percent allowance for charitable contributions under sec. 170(b)(1)(A), I.R.C. 1954. Held, further, petitioners have not met their burden of proving that an expenditure for a garden party was motivated primarily by business rather than personal consideration and therefore such expense is nondeductible under sec. 262, I.R.C. 1954.
1Opinion of the Court
Fat, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for the taxable year 1961 in the amount of $413.24.
The issues for determination are (1) whether contributions made by petitioners to the Missionary Dentist, Inc. (a.k.a. Worldwide Dental Health Service), were made to a church, educational organization, or a hospital within the meaning of section 170(b) (1) (A) of the Internal Revenue Code of 19541 and (2) whether the expenses of a garden party given by petitioners are properly deductible as ordinary and necessary business expenses of Vaughn V. Chapman’s dental…
Also in this document: Concurrence.
2Cases cited3 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Boehm v. CommissionerUnited States Board of Tax Appeals · 1937
- Bennett's Travel Bureau, Inc. v. CommissionerUnited States Tax Court · 1957
3Cited by70 opinions
- St. Martin Evangelical Lutheran Church v. South DakotaSupreme Court of the United States · 1981
- Hynes v. CommissionerUnited States Tax Court · 1980
- Buddy Schoellkopf Products, Inc. v. CommissionerUnited States Tax Court · 1975
- American Guidance Foundation, Inc. v. United StatesDistrict Court, District of Columbia · 1980
- Church of the Visible Intelligence that Governs Universe v. United StatesUnited States Court of Claims · 1983
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