- 31 - 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.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: March 27, 2008