COOLEY v. C. I. R.

No. 129, Docket 26195.

283 F.2d 945 (1960)

Jacob J. COOLEY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided November 25, 1960.


Attorney(s) appearing for the Case

T. Holmes Bracken, New Haven, for petitioner.

Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Meyer Rothwacks and Claron C. Spencer, Attorneys, Department of Justice, Washington, D. C., for respondent.

Before SWAN, CLARK and MEDINA, Circuit Judges.


PER CURIAM.

In January 1952 the taxpayer purchased from General Motors Corporation thirteen Chevrolet automobiles on the express condition that he would donate them to the United Jewish Appeal for export to the State of Israel for use by disabled veterans. Their cost to him was $17,581.72 but their fair market value at retail, if he had been privileged to sell them, was $24,700. He claimed the latter sum as a charitable deduction under Section 23(o) of the...

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