Legal Opinion

Sutton v. Commissioner

United States Tax Court

Decided November 17, 1971No. Docket No. 4986-69PublishedCited by 50 opinions

Held, the conveyance to the City of Westminister, Calif., of an easement over a strip of land for use in widening the street adjoining petitioners' property was not a charitable contribution. Sec. 170, I.R.C. 1954.

1Opinion of the Court

FeatherstoN, Judge'-

Respondent determined a deficiency in petitioners’ Federal income taxes for 1966 in the amount of $2,688.72. The sole issue for decision is whether petitioners are entitled to deduct, as a charitable contribution under section 170,1 the value of certain property over which petitioners dedicated a permanent easement to the City of Westminster, Calif., for its use in widening a street.

FINDINGS OF FACT

Larry G. Sutton (hereinafter referred to as Sutton) and Marjorie V. Sutton, husband and wife, were legal residents of Newport Beach, Calif., at the time their petition was…

2Cases cited10 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Bogardus v. CommissionerSupreme Court of the United States · 1937
  3. Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
  4. Robert C. Stubbs and Mary Ann Stubbs, Husband and Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1970
  5. United States v. Transamerica Corporation, Transamerica Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1968

5 more not listed; retrieve them via the Exa API.

3Cited by50 opinions

  1. Foster v. Comm'rUnited States Tax Court · 1983
  2. Stark v. CommissionerUnited States Tax Court · 1986
  3. Elrod v. CommissionerUnited States Tax Court · 1986
  4. Seed v. CommissionerUnited States Tax Court · 1971
  5. Louisville & N. R. Co. v. CommissionerUnited States Tax Court · 1976

45 more not listed; retrieve them via the Exa API.

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