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Brother Ploeger signed on behalf of the University the
“Donee Acknowledgment” in Part IV of Section B of Form 8283 and
acknowledged therein that the University received the claimed
donated property on August 1, 1991. Nowhere in their joint
return did petitioners indicate that either MHR Properties’
leasehold interest or MHR Properties’ purchase option was termi-
nated as of a date other than August 1, 1991. The date of
Brother Ploeger’s signature as reported in Part IV of Section B
of Form 8283 was September 21, 1994.
In the notice issued to petitioners for 1991, respondent
determined, inter alia, to disallow the $111,500 claimed noncash
charitable contribution to the University. Respondent further
determined in the notice that petitioners are liable for 1991 for
the accuracy-related penalty under section 6662(a).
OPINION
Petitioners bear the burden of proving that the determina-
tions in the notice are erroneous. See Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933).
Claimed Charitable Contribution Deduction
In their joint return and in the petition, petitioners
claimed a charitable contribution deduction under section 170(a)
with respect to MHR Properties’ purchase option. However,
petitioners argued at trial, and they argue on brief, that they
are entitled to a charitable contribution deduction with respect
to both MHR Properties’ leasehold interest and MHR Properties’
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