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ROLFS v. COMMISSIONER

Docket No. 9377-04.

135 T.C. 471 (2010)

THEODORE R. ROLFS AND JULIA A. GALLAGER, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 4, 2010.

Attorney(s) appearing for the Case

Michael G. Goller, Robert E. Dallman, and Michelle L. Mukhtar, for petitioners.

James E. Schacht and Mark J. Miller, for respondent.

GALE, Judge:

Respondent determined a deficiency of $19,940 in petitioners' Federal income tax for 1998 and an accuracy-related penalty equal to 20 percent of the underpayment under section 6662(a).1 By their amended petition, petitioners aver that they are entitled to a charitable contribution deduction of $235,350, rather than the $76,000 claimed on their return, as a result of a donation of a house to a local volunteer fire department...

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