-7- purported donation of the 1988 gift land.5 Petitioners subsequently filed amended 1989 and 1990 returns, claiming charitable contribution carryforwards. On their 1991 and 1992 Federal income tax returns, petitioners carried forward charitable contribution deductions in the respective amounts of $66,741 and $103,784, in connection with the purported donation of the 1988 gift land. These are the deductions at issue herein. Notice of Deficiency and Amended Answer In the notice of deficiency, respondent disallowed petitioners' 1991 and 1992 charitable contribution deductions because petitioners failed to establish that they had legal title to the donated property. In the amended answer, respondent alleged, among other things, that because the 1988 gift land was at 5 Petitioners attached the following explanation to their 1988 amended return: The taxpayers made a gift of appreciated real property to a charitable donee on December 29, 1988. At the time their 1988 return was filed, however, the taxpayers had not been able to obtain the donee's acknowledgment of the gift on Form 8283. As a result, and acting in accordance with the substantiation requirements of Treas. Regs. section 1.170A-13(c)(2), the taxpayers did not claim a deduction related to the gift on the originally filed return. Subsequently the taxpayers obtained the donee's acknowledgment of the gift on Form 8283 and now file this amended return for the purpose of claiming the deduction as herein set forth.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011