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that the resulting gift to MRDF was $720,000 ($810,000 gross
value of stock less $90,000 received from MRDF).
Petitioners attached to their 1994 income tax return a
letter dated January 4, 1995, from the treasurer of MRDF to Mr.
Koblick and the two other shareholders of Sealodge. The MRDF
letter confirmed the transfer of the MRDF shares and valued those
shares based on a report of Edward M. Geiger, a consulting
engineer. Mr. Geiger’s report and another report prepared by
Thomas Ferguson were also attached to the 1994 return.
Petitioners claimed charitable contribution deductions on
their Federal income tax returns for their donation of Sealodge
stock to MRDF as follows:
Year Amount
1994 $55,411
1995 71,138
1996 65,889
1997 103,568
1998 357,601
1999 66,221
Petitioners timely filed their Forms 1040 for the calendar
years 1998 and 1999 with the Internal Revenue Service in Atlanta,
Georgia, on August 13, 1999, and August 19, 2000, respectively.
Respondent determined in the notice of deficiency for 1998
and 1999 that petitioners owed deficiencies of $84,956 and
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