- 146 - C. Deduction for Charitable Contribution Claimed for Property Transferred to Kenyon College On the 1979 income tax return petitioner claimed a charitable contribution deduction in the amount of $657,000 arising out of real estate donated to Kenyon College. This deduction was reduced to zero in the notice of deficiency by ordinary income realized. The claimed charitable contribution consisted of property owned by the McZand Corporation, a subchapter S corporation, and listed on its tax return as being acquired for the following amounts and on dates of purchase indicated: Land Date Amount Stoneridge Land 09/77 $511,000 Westgrove Land 05/78 438,000 Pickerington Land 05/78 411,000 The $657,000 amount of the charitable contribution claimed by petitioner was calculated by determining that the fair market value of the Stoneridge, Westgrove, and Pickerington tracts was $1,360,000 (the sum of the properties' costs) less mortgages of $703,000 for a net value after debt of $657,000. The McZand Corporation was involved in real estate development. Initially, petitioner and his children owned 50 percent of McZand Corporation's stock, and David William McCabe, in his individual capacity or as custodian for his children, owned the remaining 50 percent. Subsequently, on October 22,Page: Previous 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 Next
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