885 Inv. Co. v. Commissioner
United States Tax Court
In 1979 and 1981, 885, a limited partnership, donated parcels of land to the city of Sacramento for use as a scenic corridor and claimed charitable contribution deductions for such transfers. In 1983, the city conveyed the donated parcels back to 885. Held: 1. No charitable contribution deduction is allowable for the 1979 and 1981 conveyances because such conveyances were subject to a condition, the occurrence of which was not so remote as to be negligible.
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In 1979 and 1981, 885, a limited partnership, donated parcels of land to the city of Sacramento for use as a scenic corridor and claimed charitable contribution deductions for such transfers. In 1983, the city conveyed the donated parcels back to 885. Held: 1. No charitable contribution deduction is allowable for the 1979 and 1981 conveyances because such conveyances were subject to a condition, the occurrence of which was not so remote as to be negligible. Sec. 1.170A-1(e), Income Tax Regs. Therefore, the individual petitioners, partners in 885, are not entitled to deduct as a charitable…
1Opinion of the Court
JACOBS, Judge:
Respondent determined the following deficiencies in and additions to petitioners’ Federal income taxes in docket No. 4560-87:
Additions to tax
Petitioner Year Deficiency Sec. 6653(a)(1)*,1 Sec. 6659
Enlow & Melena 1981 $40,650 $2,033 $11,930
Ose 1982 27,984 1,399 8,395
Edward & Karen Christenson 1981 6,473 324 1,940
Robert & Nancy Laddish 1981 5,385 269 1,616
Richard & Elnora Bradish 1981 1,971 99 591
Respondent also determined that these petitioners (individual petitioners) were hable for increased interest on tax-motivated transactions pursuant to section 6621(c).
With respect to…
2Cases cited34 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Mitchell v. United StatesSupreme Court of the United States · 1925
- Maxwell v. CommissionerUnited States Tax Court · 1986
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- Graev v. CommissionerUnited States Tax Court · 2013
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