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ADDIS v. C.I.R.

No. 02-73628.

374 F.3d 881 (2004)

Charles H. ADDIS; Cindi Addis, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed July 8, 2004.

Attorney(s) appearing for the Case

Steven Toscher, Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, CA, for the petitioners-appellants.

Steven W. Parks, Attorney, Tax Division, Department of Justice, Washington, DC, for the respondent-appellee.

Before CANBY, NOONAN, and THOMAS, Circuit Judges.

NOONAN, Circuit Judge.

Charles H. Addis and his wife Cindi Addis appeal a Tax Court judgment denying them charitable contribution deductions for their payments to the National Heritage Foundation ("NHF") in 1997 and 1998. The central question is whether 26 U.S.C. § 170(f)(8) disallows the deductions because the receipts substantiating the transfers to the NHF stated the Addises received no consideration though they expected the NHF to use their funds to pay part...

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