118 T.C. No. 19
UNITED STATES TAX COURT
JOHN C. AND TATE M. TODD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17046-99. Filed April 19, 2002.
R disallowed deductions claimed on account of a
contribution of corporate shares to a private
foundation (other than a private foundation described
in sec. 170(b)(1)(E), I.R.C.) on the alternative
grounds that the shares were not qualified appreciated
stock, within the meaning of sec. 170(e)(5)(B)(i),
I.R.C., and that the shares were not publicly traded
securities, within the meaning of sec. 1.170A-
13(c)(7)(xi), Income Tax Regs., so that the
substantiation requirements of sec. 1.170A-13(c)(1)(i),
Income Tax Regs., applied but were not satisfied.
1. Held: Deductions disallowed; the shares were
not qualified appreciated property.
2. Held, further, deductions disallowed on
alternative grounds; the shares were not publicly
traded securities, so that the substantiation
requirements were applicable but not satisfied.
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