Friedman v. Comm'r
United States Tax Court
Ps claimed charitable contribution deductions for the donation of equipment in 2001 and 2002. Ps did not strictly comply with the substantiation requirements of sec. 1.170A-13, Income Tax Regs., but they contend their documentation satisfied the substantial compliance doctrine according to Bond v. Commissioner, 100 T.C. 32, 40-41 (1993). Held: Ps did not establish substantial compliance because they did not provide adequate descriptions of the equipment and did not identify…
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Ps claimed charitable contribution deductions for the donation of equipment in 2001 and 2002. Ps did not strictly comply with the substantiation requirements of sec. 1.170A-13, Income Tax Regs., but they contend their documentation satisfied the substantial compliance doctrine according to Bond v. Commissioner, 100 T.C. 32, 40-41 (1993). Held: Ps did not establish substantial compliance because they did not provide adequate descriptions of the equipment and did not identify the valuation methods used, the manner of acquisition, and the cost bases of the equipment. Held, further, Ps'…
1Opinion of the Court
NEWTON J. AND VONISE FRIEDMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Friedman v. Comm'r
No. 19018-07
United States Tax Court
T.C. Memo 2010-45; 2010 Tax Ct. Memo LEXIS 46; 99 T.C.M. (CCH) 1175;
March 11, 2010, Filed
Ps claimed charitable contribution deductions for the donation of equipment in 2001 and 2002. Ps did not strictly comply with the substantiation requirements of sec. 1.170A-13, Income Tax Regs., but they contend their documentation satisfied the substantial compliance doctrine according to Bond v. Commissioner, 100 T.C. 32, 40-41 (1993).
Held: Ps did not establish…
2Cases cited15 opinions
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Bond v. CommissionerUnited States Tax Court · 1993
- Taylor v. CommissionerUnited States Tax Court · 1977
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- Belair Woods, LLC, Effingham Managers, LLC, Tax Matters Partner v. CommissionerUnited States Tax Court · 2018
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