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ESTATE OF WARDWELL v. COMMISSIONER

Docket No. 79892.

35 T.C. 443 (1960)

ESTATE OF O. J. WARDWELL, DECEASED, RUTH A. INGERSOLL, ADMINISTRATRIX WITH WILL ANNEXED; AND ESTATE OF MARJORIE M. WARDWELL, DECEASED, RUTH A. INGERSOLL, EXECUTRIX, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 27, 1960.

Attorney(s) appearing for the Case

Maurice E. Stark, Esq., for the petitioners.

Richard J. Shipley, Esq., for the respondent.

MULRONEY, Judge:

The respondent determined a deficiency in the income tax of decedents, O. J. and Marjorie M. Wardwell, for the year 1956 in the amount of $661.34.

The question is whether a $7,500 payment by Marjorie M. Wardwell to Friendship Haven, Inc., was deductible as a charitable contribution under section 170(c) of the Internal Revenue Code of 1954.1

FINDINGS OF FACT.

Some of the facts are stipulated...

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