- 3 -
After concessions,3 the issues for decision are: (1) The
fair market value of improved real property and personal property
donated by petitioners to an eligible charitable donee for
purposes of determining the allowable charitable contribution
deductions under section 170 to which petitioners were entitled
for 1986, the year of the gift, and for the years 1988, 1989,
1990, and 1991 by way of carryovers; and (2) whether petitioner
Justin M. Jacobs, Jr. is liable for an addition to tax under
section 6653(a) for 1988 and accuracy-related penalties under
section 6662(a) for 1989 and 1990.
We find and hold that the value of the improved real
property was $3,100,000, and that the value of the personal
property was $96,000, for a total of $3,196,000 when the gift was
made. We hold that petitioner Justin M. Jacobs, Jr. is not
liable for the addition to tax and accuracy-related penalties for
the years at issue.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
3 Respondent conceded that petitioner Jane Crocker is not
liable for the addition to tax and penalties for the taxable
years at issue. The parties agree that petitioners are entitled
to an investment interest carryover deduction from taxable year
1987 to taxable year 1988 and subsequent years in the total
amount of $411,539.
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