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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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