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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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