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FORTE v. COMMISSIONER

Docket No. 26782-88.

61 T.C.M. 1754 (1991)

T.C. Memo. 1991-36

Orville W. Forte, Jr. and Estate of Constance S. Forte, Deceased, Orville W. Forte, Jr., Executor v. Commissioner.

United States Tax Court.

Filed January 29, 1991.

Attorney(s) appearing for the Case

Carl R. Croce, One Boston Place, Boston, Mass., for the petitioners. Madlyn B. Coyne, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies of $78,633 and $51,742 in Orville and Constance Forte's 1981 and 1982 Federal income tax, respectively. After concessions by both parties, the sole issue involves the value of property contributed by the Fortes in 1981 to the State of New Hampshire Fish and Game Department and the consequent amount of the charitable contribution deduction allowable to them for 1981...

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