- 2 -
19321-96 1992 58,332
1993 202,886
After concessions, the only issue for decision in this case is
the fair market value of (1) real property consisting of 11.656
acres of land with a building upon it and 30.3 acres of adjoining
land on December 17, 1992, and (2) real property consisting of
50,507 square feet of land with a building upon it on September
23, 1992, for purposes of determining the proper amount of
petitioners' charitable contribution deductions.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners John T.
Talkington and Margaret K. Talkington, husband and wife, and
petitioners Henry A. Sessions and Barbara Sessions, husband and
wife, resided in Lubbock, Texas, at the time they filed their
petitions. Mr. and Mrs. Talkington and Mr. and Mrs. Sessions
filed Federal income tax returns for 1992 and 1993.
The Litton Property
The Litton property consists of: (1) A 48,215-square foot
building (the Litton building) located on 11.656 acres of platted
land rectangular in shape at the intersection of Loop 289, which
1 Unless otherwise indicated, 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.
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