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PETTY v. COMMISSIONER

Docket No. 94981.

40 T.C. 521 (1963)

NORMAN PETTY AND VIOLET PETTY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 14, 1963.

Attorney(s) appearing for the Case

John P. Dwyer, for the petitioners.

Crane C. Hauser, for the respondent.

FAY, Judge:

The respondent determined a deficiency in the petitioners' income tax for the year 1958 in the amount of $8,777.47.

The respondent has stipulated that the petitioners are entitled to one of the deductions disallowed in the deficiency notice.

The only issues remaining for decision are whether the petitioners are entitled to a charitable deduction in 1958 for the fair market value of an unsecured negotiable demand note given to a tax...

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