- 2 - All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are: (1) Whether petitioners are entitled to charitable contribution deductions in excess of the amount allowed by respondent; and (2) whether petitioners are liable for the penalty for a substantial valuation misstatement for 1994. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners resided in Rowayton, Connecticut, at the time they filed their petition. As of the time of trial, Donald Miller (Mr. Miller), the owner and operator of Miller Yacht Sales, Inc. (Miller Yacht), had been in the business of selling boats for 35 years. In November 1987, Mr. Miller sold the boat in issue in this case--a 1967 42-foot Trojan Motor Yacht with a wooden hull, gasoline- powered engines, and no fly bridge (the boat)--to a third party for $32,000 plus a trade-in valued at approximately $5,000. At the time of this sale, the boat was in above-average condition. In 1992, Mid-Atlantic Bank repossessed the boat from the third party and sold it back to Miller Yacht for $3,750. On February 13, 1992, Mr. Sergeant purchased the boat from Miller Yacht forPage: Previous 1 2 3 4 5 6 7 8 Next
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