Gabe W. Stewart, Jr., and Doris R. Stewart - Page 3

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               Respondent determined a deficiency in petitioners’ Federal             
          income tax for 1996 in the amount of $21,486, as well as an                 
          accuracy-related penalty under section 6662(a) in the amount of             
          $4,297.                                                                     
               After the parties’ agreement at trial regarding the fair               
          market value of a noncash charitable contribution of realty, the            
          issues for decision are:                                                    
               (1) Whether petitioners are entitled to a deduction for a              
          noncash charitable contribution of personalty in excess of the              
          amount allowed by respondent.  We hold that they are not.                   
               (2) Whether petitioners are liable for an accuracy-related             
          penalty under section 6662(a).  We hold that they are to the                
          extent provided herein.                                                     
               The adjustment relating to petitioners’ long-term capital              
          gain with respect to an installment sale is purely a mechanical             
          matter, the resolution of which is dependent on the parties’                
          agreement described above regarding the fair market value of                
          certain realty.                                                             
          Background                                                                  
               Some of the facts have been stipulated, and they are so                
          found.  Petitioners resided in Panama City, Florida, at the time            
          that their petition was filed with the Court.                               
               A.  The Winter Haven Property                                          
               During 1996, petitioners were contacted by the Auburndale              






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