John T. and Linda L. Hewitt - Page 2

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               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.                                                               
               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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