-430-
and he felt an obligation to shoulder a share of the loss because
he had acted as a “broker”. Petitioners’ Reply Brief at 1407.
Although respondent argued on brief that his determination
disallowing the deduction should be sustained, respondent
conceded in his objection to the STJ report that this
transaction, like several of the transactions Kanter engaged in
with The Five, served to demonstrate that Kanter routinely used
his business and professional contacts to assist clients in
obtaining business or in raising capital for business ventures.
Citing the Court of Appeals for the Seventh Circuit’s treatment
of this issue in Estate of Kanter v. Commissioner, 337 F.3d at
855-856, respondent concedes Kanter is entitled to the disputed
deduction. We accept respondent’s concession of this issue.
Issue XXI. Whether the Kanters Are Entitled to a Deduction for a
Charitable Contribution to the Jewish United Fund for
1982 (STJ report at 177-180)
FINDINGS OF FACT
Sometime during 1982, Jewish United Fund (JUF) solicited
Kanter for a donation. On or about December 17, 1982, THC
executed a $15,000 promissory note, payable to Kanter, due on
March 1, 1983, and bearing interest at 12 percent per annum. On
December 27, 1982, THC enclosed in a letter to JUF (1) the
$15,000 promissory note payable to Kanter, and (2) Kanter’s
completed pledge card for a $15,000 donation to JUF. The
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