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appraisal, petitioners claimed a charitable contribution
deduction for the donation of the Redwood City Fox on their 1986
Federal income tax return in the amount of $5,300,000.
Petitioners attached the Ingram/Ewing appraisal and a completed
Form 8283 to their 1986 return. Petitioners claimed carryover
deductions of the remaining amount on petitioners' joint returns
for 1988 and 1989, Jacob's return for 1990, and Crocker's returns
for 1990 and 1991.
In the notices of deficiency, respondent determined that the
fair market value of the Redwood City Fox on the date of the
transfer to the Players was $1,290,000, rather than $5,300,000 as
reported by petitioners on their 1986 Federal income tax return.
Respondent's valuation was based on an appraisal performed by
Mansbach Associates, Inc., for respondent in 1994. Respondent
also determined that Crocker was liable for an addition to tax
under section 6653(a) for taxable year 1988 and accuracy-related
penalties under section 6662(a) for taxable years 1989, 1990, and
1991, and that Jacobs was liable for an addition to tax under
section 6653(a) for taxable year 1988 and accuracy-related
penalties under section 6662(a) for taxable years 1989 and 1990.
Respondent concedes that Crocker is not liable for the
addition to tax under section 6653(a) for taxable year 1988 and
the accuracy-related penalties under section 6662(a) for taxable
years 1989, 1990, and 1991.
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