Neely v. Commissioner
United States Tax Court
Petitioners made deductible charitable contributions of African art objects to qualified organizations. They also claimed deductions for fees paid to their art consultant for services relating to their art collection. Office furniture was transferred to one petitioner after his company was merged into another and his employment was terminated.
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Petitioners made deductible charitable contributions of African art objects to qualified organizations. They also claimed deductions for fees paid to their art consultant for services relating to their art collection. Office furniture was transferred to one petitioner after his company was merged into another and his employment was terminated. Legal expenses were incurred in a suit to compel disclosure of financial information brought against a closely held corporation by a minority shareholder. Held, respondent's determinations of fair market value for the donated art are sustained. Held,…
1Opinion of the Court
OPINION
Clapp, Judge:
Respondent determined deficiencies in, and additions to, petitioners’ Federal income tax as follows:
Docket No. Year Deficiency Sec. 6653(a)1 addition to tax
24184-81 1976 $182,606.00 $9,130
1977 54,592.00 2,730
1978 370,210.00 18,511
26934-82 1979 166,678.50 8,334
1980 38,944.00 1,947
The issues for decision are: (1) The amount deductible for charitable contributions of African art to qualified organizations in all years in issue; (2) whether respondent properly assessed an addition to tax under section 6653(a) for negligence or intentional disregard of rules and regulations…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Bixby v. CommissionerUnited States Tax Court · 1972
- United States v. GilmoreSupreme Court of the United States · 1963
16 more not listed; retrieve them via the Exa API.
3Cited by1,094 opinions
- Niedringhaus v. CommissionerUnited States Tax Court · 1992
- Rybak v. CommissionerUnited States Tax Court · 1988
- Allen v. CommissionerUnited States Tax Court · 1989
- Ewing v. CommissionerUnited States Tax Court · 1988
- Emmons v. CommissionerUnited States Tax Court · 1989
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