-12-
1988 gift land in December 1988. We found Mr. Kristol credible.
Thus, assuming arguendo petitioners would be entitled to
carryforwards in 1991 and 1992 arising from the 1988 charitable
contribution deduction, we would hold that the fair market value of
petitioners' interest in the 1988 gift land was no more than $5,000
in December 1988.
To reflect the foregoing,
Decision will be
entered for respondent.
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