- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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