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COHEN, Judge: Respondent determined deficiencies of $3,675
and $11,109.99 in petitioners’ Federal income tax for 2000 and
2001, respectively. Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for the
years in issue. The sole issue for decision is whether
petitioners are entitled to charitable contribution deduction
carryovers for 2000 and 2001 with respect to the 1997 donation of
a collection of copies related to one of petitioner’s client’s
case files.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated into our findings by this reference.
Petitioners resided in Oklahoma during the years in issue and at
the time they filed their petition.
From the date of his appointment by the United States
District Court in May 1995 until his withdrawal in August 1997,
petitioner Leslie Stephen Jones (petitioner) was lead counsel for
the defense of Timothy McVeigh (McVeigh), who was prosecuted for
and convicted of the April 19, 1995, bombing of the Alfred P.
Murrah Federal Building in Oklahoma City, Oklahoma (the Oklahoma
City bombing). During the course of his representation of
McVeigh and for use in the preparation of his legal defense,
petitioner was periodically provided with photocopies of
documents and copies of certain tangible objects that were
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