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SHORT v. COMMISSIONER

Docket No. 13666-95.

73 T.C.M. 2937 (1997)

T.C. Memo. 1997-255

William P. Short, Jr. and Mary E. Short v. Commissioner.

United States Tax Court.

Filed June 9, 1997.

Attorney(s) appearing for the Case

Mark D. Olson, Georgetown, Del., and Eugene H. Bayard, for the petitioners. Alan R. Peregoy, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes of $5,828 for 1991 and $35,681 for 1992. These deficiencies result from respondent's disallowance of petitioners' carryforwards of the unused portions of a $5,810,000 charitable contribution deduction claimed on their 1988 amended Federal income tax return.

The issue for decision is whether petitioners made a charitable contribution...

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