Scott v. Commissioner
United States Tax Court
Petitioner Martin A. Scott purchased certain real property for purchase-money notes and deeds of trust, the principal amounts of which included a bonus discount for early payment. He then conveyed this property subject to the encumbrances to a charity which, as part of an understanding, sold the property to a limited partnership syndicated by the real estate firm which employed the petitioner.
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Petitioner Martin A. Scott purchased certain real property for purchase-money notes and deeds of trust, the principal amounts of which included a bonus discount for early payment. He then conveyed this property subject to the encumbrances to a charity which, as part of an understanding, sold the property to a limited partnership syndicated by the real estate firm which employed the petitioner. Petitioners claimed a charitable contribution deduction for their equity in the fair market value of the property. Held, the petitioners are not entitled to a charitable contribution deduction for the…
1Opinion of the Court
SteReett, Judge:
Tbe respondent determined a deficiency of $1,866 in the Federal income taxes of the petitioners for the calendar year 1967 and an addition thereto under section 6658(a)1 of $93. The issues presented for our decision are: (1) Whether the petitioners shall be allowed any deduction as a charitable contribution for the conveyance of encumbered real property to the American Physical Fitness Research Institute, Inc.; and (2) whether the petitioners are subject to the addition to tax for the taxable year 1967 under section 6653(a).
FINDINGS OF FACT
Martin A. Scott and Angela Scott are…
2Cases cited11 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Crane v. CommissionerSupreme Court of the United States · 1947
- Mayerson v. CommissionerUnited States Tax Court · 1966
- J. Bryant Kasey and Maryann Kasey v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
- Kasey v. CommissionerUnited States Tax Court · 1970
6 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- James O. Druker and Joan S. Druker, Petitioners-Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1982
- Bergersen v. CommissionerUnited States Tax Court · 1995
- Tidler v. CommissionerUnited States Tax Court · 1987
- Bender v. CommissionerUnited States Tax Court · 1985
- Carr v. CommissionerUnited States Tax Court · 1978
17 more not listed; retrieve them via the Exa API.