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JOHN ALLAN LOVE CHARITABLE FOUNDATION v. U.S.

No. 82-1639.

710 F.2d 1316 (1983)

JOHN ALLAN LOVE CHARITABLE FOUNDATION, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided June 30, 1983.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Robert A. Bernstein, James F. Miller, Attys., Tax Div., Dept. of Justice, Washington, D.C., for appellee; Thomas E. Dittmeier, U.S. Atty., St. Louis, Mo., of counsel.

Thomas E. Toney, III, St. Louis, Mo., for appellant.

Before ARNOLD and BENNETT, Circuit Judges, and HENLEY, Senior Circuit Judge.

BENNETT, Circuit Judge.

In this tax refund suit, the appellant, the John Allan Love Charitable Foundation,1 as transferee of the assets of the John Allan Love Personal Trust, seeks to recover $136,674.27 in federal income taxes and interest. The facts having been stipulated, the primary issue in this case is whether the Trust is entitled to charitable deductions under I.R.C. § 642(c)(1)...

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