William N. Kellahan, Jr. and Alice H. Kellahan - Page 2




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          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.                         




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