¶1concurring: In most cases, including this one, political contributions proceed from the donor’s desire to see his own views regarding political policy given effect. I do not believe any gift is usually involved for gift tax purposes because there is rarely, if ever, a desire to benefit the donee in his personal capacity, but rather only a desire to further the donor’s own political objectives through the candidate. Such an expenditure, given solely to be used in facilitating the propagation of views of pQlitical policy which resemble the donor’s, is no more a gift to the recipient than is an expenditure for a newspaper advertisement a gift to the paper. In either case, the recipient is primarily viewed as a means for propagating the taxpayer’s own views. I would not lay down as a matter of law that a political contribution may never be a gift. The question should be left open, for example, whether a father’s substantial contribution to his son’s candidacy might be a gift for gift tax purposes under certain circumstances. Here, however, no such facts are involved and no gift tax was due.
71 T.C. 252
Carson v. Commissioner
Decided November 22, 1978
United States Tax Court · decided 1978-11-22
Petitioners expended directly or contributed to campaign committees substantial amounts of money on behalf of candidates seeking public office during the years 1967, 1968, 1970, and 1971. Held: such expenditures do not constitute transfers taxable as gifts.
Good law ✅— No negative treatment on recordhow we know
Decision will be entered for the petitioner · Decided 1978-11-22
How this case has been cited
Cited by 13 later decisions — most recently June 1998
5 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
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