- 21 - 3. Petitioners' Valuation and Charitable Contribution Deductions Petitioners used the services of an income tax return preparer to prepare their 1985 income tax return. Petitioners requested and obtained extensions to file until October 15, 1986. The return was filed on October 13, 1986. At the behest of their income tax return preparer, petitioners obtained two appraisals of the collection, one from Sigmund Rothschild and another from F. Peter Rose. The latter appraisal, for $188,085, was used as the basis for a charitable contribution reported in petitioners' 1985 joint tax return. A copy of the report of that appraisal was attached to the return. The amount of the charitable contribution shown on the 1985 return was large enough to create a claimed carryover into succeeding tax years through 1990. Petitioners claimed that carryover in their 1986 through 1988 joint income tax returns.4 The parties executed a series of 4 Petitioners' charitable contribution deductions shown on their returns for the years at issue were as follows: Taxable Beginning Charitable Amount of Year Balance Deduction Claimed Carryover 1985 $188,085 $20,885 $167,200 1986 167,200 20,808 146,392 1987 146,392 21,763 124,629 1988 124,629 21,859 102,770 Except for an additional $162 not at issue, the charitable contribution deduction claimed for each year in issue is also the adjustment to income that formed the basis for the underpayment determined by respondent in the statutory notice of deficiency (continued...)Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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