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GUREN v. COMMISSIONER

Docket No. 7981-74.

66 T.C. 118 (1976)

SHELDON B. GUREN AND CYNTHIA M. GUREN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 19, 1976.

Attorney(s) appearing for the Case

Robert L. Merritt, for the petitioners.

Robert N. Armen, Jr., for the respondent.

QUEALY, Judge:

The respondent determined a deficiency of $14,955 in petitioners' Federal income tax for the taxable year 1971. The sole question for decision is whether a contribution to United Jewish Appeal, Inc., in the form of a demand promissory note constitutes "payment" within the meaning of section 170(a)(1),1 thereby entitling petitioner to a deduction of a charitable contribution for the amount of the note in the taxable...

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