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Davis v. United States

United States Supreme Court
495 U.S. 472 (1990)


Facts

Harold and Enid Davis (plaintiffs) deposited money into their dependent sons’ checking accounts. The Davises’ deposits supported the missionary work that their sons, as members of the Church of Jesus Christ of Latter-day Saints, were obligated to perform. According to church regulations, the sons were supposed to use their checking accounts solely for their missionary work, but were not legally obligated to adhere to the regulations. The Davises claimed the amount of these deposits as tax deductible under § 170 of the federal tax code. The Internal Revenue Service determined that the Davises’ payments were not tax deductible, and disallowed the deductions. The Davises paid back taxes and then sued the United States government (government) (defendant) for a refund. The United States District Court for the District of Idaho ruled for the government, and the United States Court of Appeals for the Ninth Circuit affirmed. The United States Supreme Court granted certiorari to resolve a circuit split over the tax deductibility of expenses incurred in support of a third party’s charitable work.

Rule of Law

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Issue

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Holding and Reasoning (O’Connor, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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