Bond v. Commissioner
United States Tax Court
During 1986, petitioners donated two blimps to an organization described in sec. 170(c)(2) and for income tax purposes claimed a charitable contribution deduction of $ 60,000, the value of the blimps as determined during the taxable year by petitioners' qualified appraiser who completed and signed parts II and IV of respondent's Form 8283 which was attached to petitioners' return.
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During 1986, petitioners donated two blimps to an organization described in sec. 170(c)(2) and for income tax purposes claimed a charitable contribution deduction of $ 60,000, the value of the blimps as determined during the taxable year by petitioners' qualified appraiser who completed and signed parts II and IV of respondent's Form 8283 which was attached to petitioners' return. Respondent contends that the deduction is not allowable because petitioners failed to obtain and attach to their return a qualified appraisal report as required by sec. 1.170A-13, Income Tax Regs.Held, the…
1Opinion of the Court
Shields, Judge:
This matter is before the Court at this time on a motion by each party for summary judgment under Rule 121.1
For 1986 respondent determined a deficiency in petitioners’ income tax in the amount of $29,400 and an addition to tax under section 6659 for a valuation overstatement in the amount of $8,820. However, the parties have stipulated that there was no valuation overstatement on petitioners’ return for 1986. They have also stipulated that the only issue is whether, as a matter of law, the charitable contribution deduction claimed by petitioners for the value of two thermal…
2Cases cited10 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Naftel v. CommissionerUnited States Tax Court · 1985
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
- Espinoza v. CommissionerUnited States Tax Court · 1982
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