John T. and Linda L. Hewitt - Page 1

                                   109 T.C. No. 12                                    

                               UNITED STATES TAX COURT                                

                     JOHN T. AND LINDA L. HEWITT, Petitioners v.                      
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                     

               Docket No. 17146-95.                 Filed October 29, 1997.           

                    During 1990 and 1991, Ps donated nonpublicly                      
               traded stock for which they claimed charitable                         
               contribution deductions in amounts which the parties                   
               agree represent the fair market values of such stock.                  
               Ps did not obtain qualified appraisals of the stock                    
               prior to filing their returns, and Ps did not attach a                 
               summary thereof to the returns.  Held, Ps have not                     
               substantially complied with sec. 1.170A-13, Income Tax                 
               Regs., and are not entitled to charitable contribution                 
               deductions in excess of that allowed by R.                             

               Neil L. Rose, Donna S. Rucker, and Robert E. Lee, for                  
               Deborah C. Stanley, for respondent.                                    

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