Jane Crocker, F.K.A. Jane C. Jacobs, et al. - Page 3

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               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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