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After concessions,1 the issue for decision is whether
petitioners are entitled to charitable contribution deductions
under section 1702 for 1993 and 1994 in the amounts of $126,605
and $50,513, respectively, for the donation of newspapers made in
1991 to the San Francisco Academy of Comic Art.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The first stipulation of facts, second stipulation of facts,
third stipulation of facts, and the attached exhibits are
incorporated herein by this reference. Petitioners, Mr. Arbini
(hereinafter petitioner) and Mrs. Arbini, resided in Bozeman,
Montana, and Red Bluff, California, respectively, at the time
they filed their petition.
On April 12, 1988, Robert Fagliano (Mr. Fagliano) purchased
309 leather bound volumes of various issues of three Montana
newspapers from a recycling company for $1,750. The Montana
newspapers were complete, contained comic strips, and were in
good condition. At the time of the purchase, petitioner was an
equal partner with Mr. Fagliano in a waste disposal business.
Petitioner paid Mr. Fagliano one-half of the cost of the Montana
1Respondent concedes that petitioners are not liable for the
accuracy-related penalties under sec. 6662(a) for the taxable
years 1993 and 1994.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
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