T.C. Memo. 2006-63
UNITED STATES TAX COURT
IAN G. KOBLICK AND TONYA A. KOBLICK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13808-04. Filed April 3, 2006.
V. Jean Owens, for petitioners.
Timothy Maher, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: Petitioners Ian G. and Tonya A. Koblick
(individually referred to as Mr. Koblick and Mrs. Koblick,
respectively) challenge respondent’s income tax deficiency
determination for 1998 and 1999 which is based upon the
disallowance of charitable deductions that were carried forward
from a 1994 contribution of 45 percent of the outstanding stock
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