Izen v. Comm'r
United States Tax Court
On a Form 1040X, Amended U.S. Individual Income Tax return, for 2010, filed in April 2016, P claimed a charitable contribution deduction of $338,080 for his alleged gift to a charitable organization of an interest in a 40-year-old airplane.
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On a Form 1040X, Amended U.S. Individual Income Tax return, for 2010, filed in April 2016, P claimed a charitable contribution deduction of $338,080 for his alleged gift to a charitable organization of an interest in a 40-year-old airplane. On cross-motions for partial summary judgment, R contends that P is not entitled to the claimed deduction because P failed to satisfy the substantiation requirements of I.R.C. sec. 170(f)(12), which applies to "contributions of used motor vehicles, boats, and airplanes." Under para. (12), no deduction is allowed for contributions of vehicles whose claimed…
1Opinion of the Court
JOE ALFRED IZEN, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Izen v. Comm'r
Docket No. 28358-12.
United States Tax Court
2017 U.S. Tax Ct. LEXIS 5; 148 T.C. No. 5;
March 1, 2017, Filed
An order will be issued granting respondent's motion for partial summary judgment and denying petitioner's motion for partial summary judgment.
On a Form 1040X, Amended U.S. Individual Income Tax return, for 2010, filed in April 2016, P claimed a charitable contribution deduction of $338,080 for his alleged gift to a charitable organization of an interest in a 40-year-old airplane. On cross-motions…
2Cases cited11 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Commissioner v. SimmonsCourt of Appeals for the D.C. Circuit · 2011
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