Evans v. Comm'r
United States Tax Court
Ps granted two facade easements to a qualified conservation organization and claimed a $154,350 charitable contribution deduction on their 2004 Federal income tax return. R determined a deficiency, in part, on the basis that Ps overstated the amount of their charitable contribution deduction, and R subsequently asserted an accuracy-related penalty under sec. 6662, I.R.C. Held: Ps are liable for the deficiency.
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Ps granted two facade easements to a qualified conservation organization and claimed a $154,350 charitable contribution deduction on their 2004 Federal income tax return. R determined a deficiency, in part, on the basis that Ps overstated the amount of their charitable contribution deduction, and R subsequently asserted an accuracy-related penalty under sec. 6662, I.R.C. Held: Ps are liable for the deficiency. Held, further, Ps are not liable for that portion of the accuracy-related penalty under sec. 6662, I.R.C., that relates to the disallowed charitable contribution deduction.
1Opinion of the Court
BILLY L. AND RENETTA J. EVANS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Evans v. Comm'r
Docket No. 8309-08
United States Tax Court
T.C. Memo 2010-207; 2010 Tax Ct. Memo LEXIS 242; 100 T.C.M. (CCH) 275;
September 22, 2010, Filed
Decision will be entered under Rule 155.
Ps granted two facade easements to a qualified conservation organization and claimed a $154,350 charitable contribution deduction on their 2004 Federal income tax return. R determined a deficiency, in part, on the basis that Ps overstated the amount of their charitable contribution deduction, and R subsequently…
2Cases cited36 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Freytag v. CommissionerSupreme Court of the United States · 1991
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
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