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ROLFS v. C.I.R.

No. 11-2078.

668 F.3d 888 (2012)

Theodore R. ROLFS, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided February 8, 2012.

Attorney(s) appearing for the Case

Michael G. Goller (argued), Attorney, Reinhart, Boerner, Van Deuren, Milwaukee, WI, for Petitioners-Appellants.

Tamara W. Ashford , Jonathan S. Cohen , Steven K. Uejio (argued), Attorneys, Department of Justice, Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee.

Before EASTERBROOK, Chief Judge, HAMILTON, Circuit Judge, and MYERSCOUGH, District Judge.

HAMILTON, Circuit Judge.

Taxpayers Theodore R. Rolfs and his wife Julia Gallagher (collectively, the Rolfs) purchased a three-acre lakefront property in the Village of Chenequa, Wisconsin. Not satisfied with the house that stood on the property, they decided to demolish it and build another. To accomplish the demolition, the Rolfs donated the house to the local fire department to be burned down in a firefighter training exercise. The Rolfs claimed a $76,000 charitable...

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