Ian G. Koblick and Tonya A. Koblick - Page 2

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          in Sealodge International, Inc. (Sealodge) to Maine Resources               
          Development Foundation (MRDF), a section 501(c)(3)1 charity.  The           
          issue before us is the value of the 45-percent stock ownership              
          interest in Sealodge.  As explained in more detail herein, we               
          find that the interest was worth significantly less than reported           
          by petitioners.                                                             
                                  FINDINGS OF FACT                                    
               Petitioners are husband and wife who resided in Key Largo,             
          Florida, as of the date of the filing of the petition.                      
               On December 19, 1994, Mr. Koblick transferred 11,247 shares            
          of common stock of Sealodge to MRDF.  The 11,247 shares of                  
          Sealodge stock transferred by Mr. Koblick to MRDF represented 45            
          percent of the outstanding stock of Sealodge.  There were two               
          other shareholders of Sealodge, Dr. Neil Monney (Dr. Monney), who           
          owned 45 percent, and Debra Alexander, who owned 10 percent.                
          They also transferred their shares to MRDF simultaneously with              
          Mr. Koblick’s transfer.                                                     
               Petitioners received $90,000 from MRDF in exchange for the             
          45-percent interest in Sealodge transferred to MRDF by Mr.                  
          Koblick.  On their 1994 Form 1040, U.S. Individual Income Tax               
          Return (Form 1040), petitioners claimed that the fair market                
          value of the stock in Sealodge donated to MRDF was $810,000, and            


               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       




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