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easement. Held, further, fair market value of easement
determined. Held, further, economic benefit of
charitable contribution deduction, tax-free interest,
and tax deferral from installment sale are not part of
amount realized by petitioners; amount realized and
charitable contribution determined.
James L. Thompson, Lewis R. Schumann, and Glenn M. Anderson,
for petitioners.
Susan T. Mosley and Warren P. Simonsen, for respondent.
HALPERN, Judge: These consolidated cases involve the
following determinations by respondent of deficiencies in
petitioners’ Federal income taxes:
Year Deficiency
1990 $16,910
1991 3,481
1992 7,720
1993 4,013
The issue in dispute is the amount (if any) of petitioners’
charitable contribution on account of petitioners’ conveyance to
Howard County, Maryland, in 1990 of an easement relating to
certain real property.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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