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SUNA v. COMMISSIONER OF INTERNAL REVENUE

No. 89-1311.

893 F.2d 133 (1990)

Irwin M. SUNA, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided January 12, 1990.

Attorney(s) appearing for the Case

Mark B. Cohn (argued), and Daniel R. McCarthy, McCarthy, Lebit, Crystal & Haiman, Cleveland, Ohio, for petitioners-appellants.

Peter K. Scott, I.R.S., Gary R. Allen, Acting Chief, Kimberly S. Stanley (argued), and Gilbert S. Rothenberg, U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., for respondent-appellee.

Before MARTIN and NORRIS, Circuit Judges; and CONTIE, Senior Circuit Judge.

PER CURIAM.

This is an appeal from a decision of the Tax Court, reported as Suna v. Commissioner, 57 T.C.M. (P-H) 2793, 1988 WL 125570 (1988), disallowing the taxpayers' claim that they are entitled to a charitable contribution deduction as the result of their having conveyed real property to a qualified charity. The facts of the case are clearly set out in the Tax Court Opinion.

We review findings of fact by the Tax Court under the clearly erroneous...

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