- 2 - 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 AuburndalePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011