129 T.C. No. 16
UNITED STATES TAX COURT
SHERREL AND LESLIE STEPHEN JONES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20253-04. Filed November 1, 2007.
In 1997, P, an attorney practicing in Oklahoma,
donated to a university library photocopied materials
received from the Government in connection with P’s
representation of a criminal defendant.
Held: Under Oklahoma law, an attorney does not
own his client’s case file, but rather maintains
custodial possession of the file. Because P did not
possess an ownership interest in the materials and was
thus incapable of effecting a valid gift of the
materials under Oklahoma State law, sec. 170(c),
I.R.C., precludes the charitable contribution
deduction.
Clarke Lewis Randall, for petitioners.
Elizabeth Downs, for respondent.
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