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OPINION
TANNENWALD, Judge: Respondent determined deficiencies in
petitioners' Federal income taxes and penalties under section
6662(a)1 as follows:
Year Deficiency Penalty
1990 $17,332 $3,466
1991 22,945 4,589
After concessions, the sole issue for decision is whether
petitioners should be allowed charitable deductions in amounts
greater than those allowed by respondent for gifts of nonpublicly
traded stock.
Background
This case was submitted fully stipulated under Rule 122. The
stipulation of facts and attached exhibits are incorporated
herein by this reference.
Petitioners resided in Virginia Beach, Virginia, at the time
they filed their petition. They filed their joint Federal income
tax returns for the years in issue with the Internal Revenue
Service Center, Philadelphia, Pennsylvania.
Petitioner John T. Hewitt, along with about a dozen other
investors, bought Mel Jackson's Tax Service in Tidewater,
1 Unless otherwise indicated, all statutory 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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Last modified: May 25, 2011