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In the notice of deficiency, respondent, apparently relying
on the second engineer, determined that petitioner was entitled
to claim a total of $118,000 as charitable deductions in 1991 and
1992 for the contribution of the 236 donated films. On the basis
of that determination, respondent disallowed the other half of
the claimed deductions in the amount of $118,000, resulting in
deficiencies for petitioner's 1990 and 1991 taxable years.
Thereafter, petitioner, who at the time resided in Akron, Ohio,
filed a petition with this Court.
In a letter to respondent's counsel dated April 21, 1997,
petitioner requested documents relating to the appraisal of the
donated films. Respondent refused to turn over the expert report
and objected to production. On June 2, 1997, petitioner filed a
motion to compel production of documents relating to the
appraisal of the donated films. Also, on June 2, 1997,
respondent filed a motion for leave to file amendment to answer
to petition asserting as a new matter that petitioner did not own
the donated films and was not entitled to any charitable
deductions with regard to the films. This case had been
scheduled for trial in Cleveland, Ohio, on June 2, 1997, and was
continued, and respondent's motion to amend the answer remains
outstanding.
Petitioner also filed a FOIA request with the Internal
Revenue Service seeking a copy of the expert report. Petitioner
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