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Income Tax Keyed to Lind
Alice Phelan Sullivan Corp. v. United States
Facts
Alice Phelan Sullivan Corp (Plaintiff) made two charitable conveyances of parcels in 1939 and 1940. Taxpayer deducted $4,243.49 and $4,463.44 respectively for a combined tax benefit of $1,877.49. In 1957, the donee decided not to use the parcels and reconveyed to Plaintiff. In 1957, Plaintiff did not include the $8,706.93 land value as taxable income. The Commissioner of Internal Revenue, upon audit, determined the amount was taxable income and applied the 52% corporate tax rate to determine Plaintiff was deficient by $4,527.60. Plaintiff paid deficiency and claimed a refund for $2,650.11, the amount of the deficiency in excess of the original tax benefit received by making the charitable contribution.
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