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Hill v. Commissioner

Docket No. 7058-03.

87 T.C.M. 1451 (2004)

T.C. Memo. 2004-156

Jerry L. Hill and Valerie J. Hill v. Commissioner.

United States Tax Court.

June 30, 2004.

Attorney(s) appearing for the Case

Joe Alfred Izen, Jr., for petitioners.

Huong Duong, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioners petitioned the Court to redetermine a $130,260 deficiency in their 1999 Federal income tax and a $26,052 accuracy-related penalty under section 6662(a). Following concessions, including petitioners' concession that the trust at hand (Re-Cap Trust) is disregarded for Federal income tax purposes, we decide whether petitioners may deduct certain amounts as charitable contributions. We hold they...

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