-9- that an appraisal of the subject property be obtained. TRRC retained Keith White (Mr. White) of White Realty & Appraisal to perform an appraisal of the property that was attached to TRC’s information tax return, Form 1065, U.S. Partnership Return, for 1998. Deductions at Issue TRY claimed a charitable contribution of $475,000 with respect to the subject property, although TRY purchased the subject property for $75,000 just 17 months before the date of donation. TRY included each petitioner husband and wife’s respective portion of this charitable contribution on their respective Schedules K-1, Partner’s Share of Income, Deductions, Credits, etc., for 1998. Petitioners in each docket filed joint tax returns for 1998 and claimed their proportionate share of TRC’s $475,000 charitable contribution deduction for 1998, up to the statutory limit of 30 percent of adjusted gross income. Sec. 170(b)(1)(F), 170(b)(1)(B)(I). Petitioners carried forward the remaining portion of the charitable contribution and deducted portions on their joint tax returns for 1999 and 2000, the years at issue in this case. Respondent issued deficiency notices to petitioners for 1999 and 2000 on September 16, 2003, in which respondent determined the subject property had a value of $76,200, rather than the $475,000 claimed by petitioners. Respondent accordingly partially disallowed petitioners’ deductions for the charitablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011