Hewitt v. Comm'r
United States Tax Court
During 1990 and 1991, Ps donated nonpublicly traded stock for which they claimed charitable contribution deductions in amounts which the parties agree represent the fair market values of such stock. Ps did not obtain qualified appraisals of the stock prior to filing their returns, and Ps did not attach a summary thereof to the returns.
Read the full summary
During 1990 and 1991, Ps donated nonpublicly traded stock for which they claimed charitable contribution deductions in amounts which the parties agree represent the fair market values of such stock. Ps did not obtain qualified appraisals of the stock prior to filing their returns, and Ps did not attach a summary thereof to the returns. HELD, Ps have not substantially complied with sec. 1.170A-13, Income Tax Regs., and are not entitled to charitable contribution deductions in excess of that allowed by R.
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes and penalties under section 6662(a)1 as follows:
Penalty Year Deficiency sec. 6662(a)
1990 $17,332 $3,466
1991 22,945 4,589
After concessions, the sole issue for decision is whether petitioners should be allowed charitable deductions in amounts greater than those allowed by respondent for gifts of nonpublicly traded stock.
Background
This case was submitted fully stipulated under Rule 122. The stipulation of facts and attached exhibits are incorporated herein by this reference.
Petitioners resided in…
2Cases cited8 opinions
- Bond v. CommissionerUnited States Tax Court · 1993
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- Taylor v. CommissionerUnited States Tax Court · 1977
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Cary v. CommissionerUnited States Tax Court · 1963
3 more not listed; retrieve them via the Exa API.
3Cited by53 opinions
- Scheidelman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2012
- Estate of Clause v. Comm'rUnited States Tax Court · 2004
- Jorgenson v. CommissionerUnited States Tax Court · 2000
- Dunlap v. Comm'rUnited States Tax Court · 2012
- Alli v. Comm'rUnited States Tax Court · 2014
48 more not listed; retrieve them via the Exa API.