Sherrel and Leslie Stephen Jones - Page 1

                                   129 T.C. No. 16                                    

                               UNITED STATES TAX COURT                                

                  SHERREL AND LESLIE STEPHEN JONES, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 20253-04.              Filed November 1, 2007.              

                    In 1997, P, an attorney practicing in Oklahoma,                   
               donated to a university library photocopied materials                  
               received from the Government in connection with P’s                    
               representation of a criminal defendant.                                
                    Held:  Under Oklahoma law, an attorney does not                   
               own his client’s case file, but rather maintains                       
               custodial possession of the file.  Because P did not                   
               possess an ownership interest in the materials and was                 
               thus incapable of effecting a valid gift of the                        
               materials under Oklahoma State law, sec. 170(c),                       
               I.R.C., precludes the charitable contribution                          

               Clarke Lewis Randall, for petitioners.                                 
               Elizabeth Downs, for respondent.                                       

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