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return showed charitable contribution carryover deductions of
$33,102, $37,783 and $26,154, respectively, and contained
schedules detailing these deductions. Respondent disallowed
these deductions, determining that they did not reflect
contributions paid by petitioner. Respondent reflected that
determination in a notice of deficiency issued to petitioner on
July 17, 1995.
Petitioner is the only child of Jan Stussy (Mr. Stussy).
On October 30, 1989, Mr. Stussy transferred his residence (the
Residence) in Los Angeles, California, to the Stussy Family Trust
(the Trust). The Trust was a grantor trust, of which Mr. Stussy
was the trustor and trustee, and its assets included Mr. Stussy's
paintings, drawings, photographs, and books on art (collectively,
the Artwork). The Trust document provided that, upon Mr.
Stussy's death, the Artwork would pass to a stated foundation in
New York, New York, and that the residue would pass to
petitioner.
Mr. Stussy amended the Trust twice, once on April 30, 1990,
and a second time on May 10, 1990. He amended the Trust the
first time to provide that the Artwork and certain pension
benefits would pass at his death to a charitable organization
named the Jan Stussy Foundation (the Foundation).
Contemporaneously with this amendment, Mr. Stussy signed a
license under which he gave the Foundation the exclusive right to
use four unconnected rooms (collectively, the Rooms) in the
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