-432- assert: “While a small discount for the fact that the note was not to be paid until several months after the date of contribution is perhaps required, there is no basis for disallowing the entire contribution.” Petitioners submit that, given the interest rates at the time (as reflected in the IRS’s applicable Federal rates, as well as the 12-percent interest rate set in the note itself), the 1982 deduction should be discounted not more than $300. Respondent contends the Kanters are not entitled to a charitable contribution deduction for 1982 because: (1) There was no endorsement of the THC promissory note by Kanter to JUF, and (2) the Kanters failed to establish the note’s fair market value as of the date of its purported contribution to JUF in late 1982. B. The STJ Report The STJ report recommended holding that the Kanters are entitled to a charitable contribution deduction of $14,630 for 1982 related to the JUF transaction. We reject the recommendation in the STJ report because it is erroneous as a matter of law. C. Analysis Section 170(a) generally provides that a deduction is allowed for a charitable contribution, payment of which is made within the taxable year. Payment to a charity generally occursPage: Previous 422 423 424 425 426 427 428 429 430 431 432 433 434 435 436 437 438 439 440 441 Next
Last modified: May 25, 2011