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assets associated with their medical practices in amounts
consistent with Dr. Levin's allocations, as follows:
Deduction
Docket No. Petitioner Claimed
10930-02 Derby 1$65,006
10931-02 Droubay 73,592
10932-02 Eusebio 35,978
10933-02 Harris 38,839
10934-02 Hirsch 28,619
10935-02 Smith-Hoefer 81,769
10936-02 Kennedy 240,884
10937-02 Levin 104,255
10939-02 Smith-MacLean 47,427
10941-02 Patterson 83,405
10942-02 Silva 76,045
10943-02 Women's Health Assoc. 3162,926
10945-02 Watts-White 40,475
1 Because the charitable contribution deduction claimed
on Schedule A, Itemized Deductions, of the Derbys' 1994
return ($8,913 in cash contributions plus the $65,006
noncash portion at issue in this case) exceeded 50
percent of adjusted gross income, the Derbys' 1994
charitable contribution deduction was limited to
$60,212. Respondent denied a deduction for "any amount
in excess of $8913" and increased the Derbys' income by
$51,409, although it appears that the deduction
disallowance should not have exceeded $51,299 (the
difference between $60,212 and $8,913).
2 Claimed on an amended return.
3 This is the aggregate amount of the charitable contribution
deduction related to the SMF transaction that the
partnership allocated to the two partners (Dr. Schimmel
($77,277); and Dr. Conrad-Forest ($85,699)) on the
partnership return. The Forms 8283 provided for each
partner list a charitable contribution deduction of $96,896
for each. There is no evidence in the record that accounts
for the discrepancy.
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Last modified: March 27, 2008