John T. and Linda L. Hewitt - Page 1
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109 T.C. No. 12
UNITED STATES TAX COURT
JOHN T. AND LINDA L. HEWITT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17146-95. Filed October 29, 1997.
During 1990 and 1991, Ps donated nonpublicly
traded stock for which they claimed charitable
contribution deductions in amounts which the parties
agree represent the fair market values of such stock.
Ps did not obtain qualified appraisals of the stock
prior to filing their returns, and Ps did not attach a
summary thereof to the returns. Held, Ps have not
substantially complied with sec. 1.170A-13, Income Tax
Regs., and are not entitled to charitable contribution
deductions in excess of that allowed by R.
Neil L. Rose, Donna S. Rucker, and Robert E. Lee, for
Deborah C. Stanley, for respondent.
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