James H. And Marjorie A. Morrison v. Commissioner of Internal Revenue

Fifth Circuit

James H. And Marjorie A. Morrison v. Commissioner of Internal Revenue

611 F.2d 98, 45 A.F.T.R.2d (RIA) 664, 1980 U.S. App. LEXIS 20933

CourtCourt of Appeals for the Fifth Circuit

DecidedJanuary 31, 1980

Docket79-2604

StatusPublished

This text of 611 F.2d 98 (James H. And Marjorie A. Morrison v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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James H. And Marjorie A. Morrison v. Commissioner of Internal Revenue, 611 F.2d 98, 45 A.F.T.R.2d (RIA) 664, 1980 U.S. App. LEXIS 20933 (5th Cir. 1980).

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Opinion

PER CURIAM.

Our wonder at the claims of taxpayers never ceases; it surely must be true that hope springs eternal from the breast of man. Taxpayer, a former Congressman, donated his congressional papers to a university and claimed an income tax deduction for the value of the papers. Advocating the novel theory that the tangible work product of a Congressman’s trade or business is his congressional files, which in this case consist largely of letters to and from constituents, taxpayer claims a basis of over $1.6 million dollars in the donated property, and attempts to deduct $61,100 in charitable contributions over a five-year period. Although we have no doubt that taxpayer’s services to his constituents over twenty-four years are difficult to value in monetary terms, and that many of the letters in his collection may be priceless, we agree with the Tax Court that taxpayer has failed to establish the claimed deduction, and affirm on the basis of Judge Wilbur’s excellent opinion, 71 T.C. 683 (1979).

AFFIRMED.

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PER CURIAM.

Our wonder at the claims of taxpayers never ceases; it surely must be true that hope springs eternal from the breast of man. Taxpayer, a former Congressman, donated his congressional papers to a university and claimed an income tax deduction for the value of the papers. Advocating the novel theory that the tangible work product of a Congressman’s trade or business is his congressional files, which in this case consist largely of letters to and from constituents, taxpayer claims a basis of over $1.6 million dollars in the donated property, and attempts to deduct $61,100 in charitable contributions over a five-year period. Although we have no doubt that taxpayer’s services to his constituents over twenty-four years are difficult to value in monetary terms, and that many of the letters in his collection may be priceless, we agree with the Tax Court that taxpayer has failed to establish the claimed deduction, and affirm on the basis of Judge Wilbur’s excellent opinion, 71 T.C. 683 (1979).

AFFIRMED.

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611 F.2d 98, 45 A.F.T.R.2d (RIA) 664, 1980 U.S. App. LEXIS 20933, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-h-and-marjorie-a-morrison-v-commissioner-of-internal-revenue-ca5-1980.

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