Kaufman v. Commissioner
United States Tax Court
In Kaufman v. Commissioner, 134 T.C. 182 (2010), we granted R partial summary judgment, sustaining his disallowance of charitable contribution deductions Ps claimed on account of PW's grant to N of a facade easement burdening their residence. Ps ask that we reconsider our grant of partial summary judgment.
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In Kaufman v. Commissioner, 134 T.C. 182 (2010), we granted R partial summary judgment, sustaining his disallowance of charitable contribution deductions Ps claimed on account of PW's grant to N of a facade easement burdening their residence. Ps ask that we reconsider our grant of partial summary judgment. We must also address PW's cash contributions to N and R's determination of accuracy-related penalties. 1. Held: We did not err in Kaufman v. Commissioner, supra, in concluding that the contribution of the facade easement failed as a matter of law to comply with the…
1Opinion of the Court
Halpern, Judge:
Respondent 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
The deficiencies respondent determined result from his dis-allowance of petitioners’ deductions for contributions of a facade easement burdening their residence (the facade easement) and of cash to the National Architectural Trust (NAT). The penalties are accuracy-related penalties relating to those deductions. By amendment to answer, respondent asserted an increased…
2Cases cited14 opinions
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Hernandez v. CommissionerSupreme Court of the United States · 1989
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Shea v. CommissionerUnited States Tax Court · 1999
- United States v. American Bar EndowmentSupreme Court of the United States · 1986
9 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Mitchell v. CommissionerCourt of Appeals for the Tenth Circuit · 2015
- Scheidelman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2012
- Kaufman v. ShulmanCourt of Appeals for the First Circuit · 2012
- Carroll v. Comm'rUnited States Tax Court · 2016
- Dunlap v. Comm'rUnited States Tax Court · 2012
16 more not listed; retrieve them via the Exa API.