Sherif S. Abdelhak a.k.a. Samuel A. Abel - Page 3

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               (6)  whether petitioner is liable for additions to tax under           
          section 6651(a)(1) for tax years 1998, 1999, and 2000.  We hold             
          that he is.                                                                 
               (7)  whether petitioner is liable for accuracy-related                 
          penalties under section 6662(a) for disallowed deductions.  We              
          hold that he is not liable for those penalties in 1998 and 1999.            
                                     Background                                       
               Petitioner was a resident of Prospect, Kentucky, at the time           
          he filed his petition.  Petitioner was the former president and             
          chief executive officer (CEO) of the Allegheny Health Education &           
          Research Foundation (AHERF), a Pennsylvania corporation.  AHERF             
          terminated petitioner in June 1998 and filed chapter 11                     
          bankruptcy proceedings 1 month later in July of that year.                  
          A.  1998 Charitable Deduction                                               
               In 1990, petitioner sold his home to a subsidiary of AHERF,            
          Jellico, Inc. (Jellico).  In 1992, petitioner signed a land                 
          installment contract with Jellico to repurchase the home for                
          $1,280,000 with payment spread over 20 years.  The terms of this            
          contract required petitioner to pay 5 percent of the principal              
          ($64,000) each April 30th and interest payments of 7.5 percent on           
          the remaining principal each October 30th.  The contract also               
          required petitioner to pay all taxes due on the residence.                  
          Jellico retained title during the contract period and would                 
          transfer title when petitioner paid the full contract price.  If            






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