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thousands of shares of Jackson Hewitt stock were traded between
1990 and 1992 for about 80 individual accounts.
On January 29, 1994, the company began trading on NASDAQ.
Prior to January of 1994, Jackson Hewitt stock did not qualify as
"publicly traded securities" under section 1.170A-13(c)(7)(xi),
Income Tax Regs.
Petitioners filed timely joint Federal income tax returns
for the taxable years 1990 and 1991. Attached to petitioners'
1990 return were Schedule A (Itemized Deductions), noting Gifts
to Charity other than cash or check in the amount of $35,745,2
and Form 8283 (Noncash Contributions). In section B of Form 8283
(Appraisal Summary of $5000 or More Items), petitioners reported
the donation of two blocks of stock valued at $26,000 and $7,000,
respectively, which they reported as acquired by purchase on
August 14, 1982, for $522 and $131, respectively, and for which
they claimed deductions of $26,000 and $7,000, respectively.
Attached to petitioners' 1991 Form 1040 were Schedule A,
noting Gifts to Charity other than cash or check in the amount of
$89,479,3 and Form 8283. In section A of Form 8283 (items of
$5000 or less and certain publicly traded securities),
petitioners reported a contribution to the foundation of stock
acquired by purchase on August 1, 1982, with a basis of $2,832
2 This amount includes $2,745 in gifts not at issue.
3 This amount includes $1,479 in gifts not at issue.
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