Jerrold E. and Helen C. Arbini - Page 2

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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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