Kaufman v. Commissioner
United States Tax Court
In 2003, Ps transferred a facade easement and cash to a qualified organization. With respect to the facade easement contribution, Ps claimed a charitable contribution deduction in 2003 and a corresponding carryover deduction in 2004; with respect to the cash contribution, Ps claimed a charitable contribution deduction in 2003. R disallowed the deductions, which led to deficiencies. R also determined accuracy-related penalties under sec. 6662, I.R.C.
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In 2003, Ps transferred a facade easement and cash to a qualified organization. With respect to the facade easement contribution, Ps claimed a charitable contribution deduction in 2003 and a corresponding carryover deduction in 2004; with respect to the cash contribution, Ps claimed a charitable contribution deduction in 2003. R disallowed the deductions, which led to deficiencies. R also determined accuracy-related penalties under sec. 6662, I.R.C. R has moved for summary judgment. Ps object. 1. Held: With respect to the facade easement contribution, Ps have failed to raise any genuine issue…
1Opinion of the Court
OPINION
Halpern, Judge:
Respondent has determined deficiencies in, and penalties with respect to, petitioners’ Federal income tax, as follows:
Penalties
Year Deficiency Sec. 6662(a) Sec. 6662(h)
2003 $39,081 $1,097 $13,439
2004 36,340 - - - 14,536
In 2003, petitioners contributed a facade easement and cash to the National Architectural Trust (nat). With respect to the facade easement contribution, petitioners claimed a charitable contribution deduction in 2003 and a corresponding carryover deduction in 2004; with respect to the cash contribution, they claimed a charitable contribution deduction in…
2Cases cited3 opinions
- Hernandez v. CommissionerSupreme Court of the United States · 1989
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
- Anonymous v. CommissionerUnited States Tax Court · 2010
3Cited by20 opinions
- Kaufman v. ShulmanCourt of Appeals for the First Circuit · 2012
- Kaufman v. CommissionerUnited States Tax Court · 2011
- Carroll v. Comm'rUnited States Tax Court · 2016
- Mitchell v. CommissionerUnited States Tax Court · 2012
- 1982 East, LLC v. Comm'rUnited States Tax Court · 2011
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