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THORNTON v. COMMISSIONER

Docket No. 38315-87.

57 T.C.M. 320 (1989)

T.C. Memo. 1989-214

William Thornton and Barbara Thornton v. Commissioner

United States Tax Court.

Filed May 4, 1989.

Attorney(s) appearing for the Case

Roland K. Martin, Jr., 50 W. Liberty St., Reno, Nev., for the petitioners. Karen Quesnel, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for their 1981 and 1982 taxable years in the amounts of $35,495 and $82,205, respectively. The parties having reached agreement with respect to all other issues raised, the sole issue for decision is whether section 170(e)(1)(A)1 limits the amount of petitioners' charitable contribution deduction to petitioners...

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