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CARSON v. C. I. R.

No. 79-1303.

641 F.2d 864 (1981)

David W. CARSON and Marjorie E. Carson, Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Tenth Circuit.

Decided March 2, 1981.

Attorney(s) appearing for the Case

Scott I. Asner of Carson, Fields & Boal, Kansas City, Kan., for appellees.

Robert A. Bernstein, Washington, D. C. (Gilbert E. Andrews and Joan I. Oppenheimer, Attys., Tax Div., Dept. of Justice, and M. Carr Ferguson, Asst. Atty. Gen., Washington, D. C., with him on the brief), for appellant.

Before McWILLIAMS, McKAY and LOGAN, Circuit Judges.

McWILLIAMS, Circuit Judge.

This is an appeal pursuant to I.R.C. § 74821 from a decision of the United States Tax Court. Carson, the taxpayer,2 made campaign contributions totaling $209,472.25 during 1967, 1968, 1970, and 1971. The taxpayer filed Federal Gift Tax returns for those periods but didn't report any of his political contributions. After reviewing such returns, the Commissioner

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