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VIRALAM v. COMMISSIONER

Docket No. 21355-03.

136 T.C. 151 (2011)

SETTY GUNDANNA AND PRABHAVATHI KATTA VIRALAM, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 14, 2011.

Attorney(s) appearing for the Case

Michael C. Durney , for petitioners.

Thomas A. Dombrowski and Mark A. Weiner , for respondent.

GALE, Judge:

Respondent determined a deficiency of $91,948 and an accuracy-related penalty of $18,389 with respect to petitioners' 1998 Federal income tax.

The issues for decision are: (1) Whether petitioners are entitled to a charitable contribution deduction under section 1701 of $263,933 for purported transfers of appreciated stocks and cash to the xélan Foundation; (2) whether petitioners must include in gross income...

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