# Perlmutter v. Commissioner > United States Tax Court · December 27, 1965 · 45 T.C. 311 URL: https://www.frixlaw.com/law-library/cases/4480295 ## Case - **Full name:** Jordon and Essie Perlmutter, 1 v. Commissioner of Internal Revenue - **Court:** United States Tax Court - **Decided:** December 27, 1965 - **Citations:** 45 T.C. 311; 1965 U.S. Tax Ct. LEXIS 2 - **Precedential status:** Published - **Opinion:** Concurrence by Fat - **Judges:** Tannenwald,Drennen,Fay - **Cited by:** 44 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4480295 ## Opinion text Fat, J., concurring: I agree with the majority that the transfers of property in question, because petitioners received a direct benefit therefor, do not qualify as charitable contributions under section 170(c). However, I believe that the only direct benefit received by petitioners from the transfers was the avoidance of “considerable and protracted difficulty” in obtaining the county’s approval of their development plans. 1 I disagree with the majority opinion to the extent to which it implies that the existence of school and recreational facilities on the transferred land also constitutes a direct benefit which alone would disqualify the transfers as charitable contributions. Such benefit seems to me to be of an incidental nature. Or the county’s approval itself if the regulation requiring the transfers was constitutionally valid. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4480295. Public record. Not legal advice.