-431- December 27, 1982, letter stated: “THC will pay its note to Kanter, who will, in turn, see to providing these funds to JUF.” In a letter to Kanter dated December 30, 1982, JUF acknowledged its receipt of the THC promissory note. The December 30, 1982, letter further stated that “This note has been assigned by you to * * * JUF as a charitable contribution, and we are pleased to accept it as such.” On February 28, 1983, THC paid to Kanter the full $15,000 in principal due on the promissory note, plus interest of $370. On that same date, Kanter then paid $15,000 to JUF by issuing to JUF his own $15,000 check. Kanter did not pay over to JUF the $370 in interest he received on the THC promissory note. On their 1982 income tax return, the Kanters claimed a $15,000 charitable deduction for Kanter’s contribution to JUF. On their 1983 income tax return, the Kanters reported the $370 in interest THC paid on the THC note as interest income. Respondent disallowed the $15,000 JUF charitable contribution deduction claimed by the Kanters. OPINION A. The Parties’ Arguments Petitioners contend they are entitled to a charitable contribution deduction for 1982 of at least $14,700, which they maintain was the THC promissory note’s fair market value on the date of its contribution to JUF in December 1982. PetitionersPage: Previous 421 422 423 424 425 426 427 428 429 430 431 432 433 434 435 436 437 438 439 440 Next
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