ALLEN v. COMMISSIONER

Docket No. 2501-70.

57 T.C. 12 (1971)

JOHN G. ALLEN AND MAXINE S. ALLEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 4, 1971.


Attorney(s) appearing for the Case

Joseph C. Buck, for the petitioners.

John D. Steele, Jr., for the respondent.


OPINION

IRWIN, Judge:

Respondent has determined deficiencies in petitioners' income tax for the taxable years 1966 and 1967 in the amounts of $3,303.73 and $1,440, respectively. The only issue presented is whether petitioners, having made a gift of a 5-year rent-free lease to a charitable organization in 1965, were correct in taking charitable contribution deductions equal to the annual fair rental value of the property in each of the years of the...

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