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CARTER v. U.S.

No. 90-16683.

973 F.2d 1479 (1992)

Jay CARTER; Joan H. Carter, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 1, 1992.

Attorney(s) appearing for the Case

Edward O.C. Ord, Ord & Norman, San Francisco, Cal., for plaintiffs-appellants.

Paula K. Speck, Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant-appellee.

Before: TANG, PREGERSON, and BOOCHEVER, Circuit Judges.

BOOCHEVER, Circuit Judge:

Jay and Joan Carter appeal the entry of summary judgment against them in their tax refund suit challenging the Internal Revenue Service's disallowance of a deduction for charitable contributions in 1983. We affirm the district court's denial of the Carters' summary judgment motion, but reverse its grant of the IRS's summary judgment motion and remand for trial.

BACKGROUND

The Carters founded the Psychal Physionic Universal...

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