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FORRER v. COMMISSIONER

Docket No. 8718-78.

42 T.C.M. 613 (1981)

T.C. Memo. 1981-418

Gordon Randolph Forrer v. Commissioner.

United States Tax Court.

Filed August 11, 1981.

Attorney(s) appearing for the Case

Gordon Randolph Forrer, pro se. William F. Garrow, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes for the calendar years 1973 and 1974 in the respective amounts of $20,200.60 and $18,242.70. The sole issue for decision is whether section 170(e)(1)(A)1 precludes a charitable contribution deduction and carryover claimed by petitioner for the donation of a royalty agreement to a qualified donee.

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