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FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulations of facts, with accompanying exhibits, are
incorporated herein by this reference.
Residence
Petitioners resided in Greeley, Colorado, at the time the
petition was filed.
The Foundation and Contribution Thereto
On December 20, 1994, petitioners formed the Todd Family
Foundation (the foundation), a Colorado nonprofit corporation.
On December 27, 1994, petitioner John C. Todd (petitioner)
transferred 6,350 shares of stock (the transfer date, the
transfer, and the shares, respectively) in Union Colony Bancorp
(Bancorp), a Colorado corporation, to the foundation. On the
transfer date, the foundation was a private foundation (as
defined in section 509(a)), other than a private foundation
described in section 170(b)(1)(E).
Petitioners’ Tax Returns
Petitioners filed a Form 1040, U.S. Individual Income Tax
Return (the Form 1040), for 1994. In calculating their taxable
income shown on the Form 1040, petitioners claimed a deduction
for a charitable contribution on account of the transfer.
Attached to the Form 1040 is a Form 8283, Noncash Charitable
Contributions (the Form 8283), on which petitioners provided
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Last modified: May 25, 2011