- 2 - Unless otherwise noted, 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. After concessions, we must decide the following issues1: (1) The value of real property, 4.75 acres on which is located a manmade canal, that petitioners donated to the South Carolina Public Service Authority as a charitable contribution. We hold that the value is no higher than the amount determined by respondent, $5,950. (2) Whether petitioners are liable for the addition to tax pursuant to section 6651(a) for 1990. We hold that they are not. (3) Whether petitioners are liable for accuracy-related penalties in increased amounts pursuant to section 6662(h) for 1990 and 1992. We hold that they are. FINDINGS OF FACT Some of the facts have been stipulated and are so found. We incorporate by this reference the stipulation of facts and attached exhibits. At the time of filing the petition, petitioners resided in Kingstree, South Carolina. The real property that is the subject of the dispute in this case was acquired by G. H. Hardy in 1971 as part of a 15-acre 1 At trial, petitioners sought to amend their petition to aver that certain income reported in 1992 had been reported twice. This matter will be disposed of separately.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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