John C. and Tate M. Todd, (2002)
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John C. and Tate M. Todd, (2002)
118 T.C. No. 19
UNITED STATES TAX COURT JOHN C. AND TATE M. TODD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17046-99. Filed April 19, 2002.R disallowed deductions claimed on account of a contribution of corporate shares to a private foundation (other than a private foundation described in sec. 170(b)(1)(E), I.R.C.) on the alternative grounds that the shares were not qualified appreciated stock, within the meaning of sec. 170(e)(5)(B)(i), I.R.C., and that the shares were not publicly traded securities, within the meaning of sec. 1.170A-13(c)(7)(xi), Income Tax Regs., so that the substantiation requirements of sec. 1.170A-13(c)(1)(i), Income Tax Regs., applied but were not satisfied. 1. Held: Deductions disallowed; the shares were not qualified appreciated property. 2. Held, further, deductions disallowed on alternative grounds; the shares were not publicly traded securities, so that the substantiation requirements were applicable but not satisfied.Richard C. Kaufman, for petitioners. Frederick J. Lockhart, Jr., for respondent.HALPERN, Judge: By notice of deficiency dated August 13, 1999 (the notice), respondent determined deficiencies in petitioners' Federal income tax liabilities for petitioners' taxable (calendar) years 1994 through 1997 (the audit years) of $14,181, $61,540, $88,832, and $33,971, respectively. Among the adjustments giving rise to respondent's determination of deficiencies is respondent's disallowance of deductions for charitable contributions p...See the full content of this document
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