Orin R. Woodbury and Imogene R. Woodbury v. Commissioner of Internal Revenue

SEYMOUR, Circuit Judge.

Petitioners appeal from the judgment and decision of the United States Tax Court which denied their petition for review of the Commissioner’s finding of tax deficiencies. The Tax Court rejected petitioners’ argument that their election to use the “fifty-percent method” in calculating their charitable contribution deduction was invalid and, in the alternative, that the election was subsequently revocable by them. We likewise reject petitioners’ arguments and, for the reasons set forth below, we affirm. 1

Petitioners are taxpayers who, in 1977, donated their entire…