§1701

In the FPA respondent disallowed a charitable contribution deduction under section 1701 and asserted penalties.

§§ 1701-1750, and the Housing and Community Development Act of 1987, § 421, Pub. L. No. 100-242, 101 Stat. 1815, 1913 (codified as amended at 12 U.S.C. § 1715z-4a), for the recovery of Center assets and income. The government’s complaint alleged that the owners used the Center’s assets and income in breach of the regulatory agreement terms. The comp

After concessions two questions remain for decision, which re- spondent has presented by Motion for Partial Summary Judgment: (1) whether petitioners are entitled under section 1701 to noncash char- itable contribution deductions for 2015 and 2016 for portions of the crops 1 Unless otherwise indicated, all statutory references are to the Internal Reve- nue Code, Title 26 U.S.C.

MEMORANDUM OPINION GREAVES, Judge: Section 1701 permits taxpayers to deduct charitable contributions made during a taxable year, provided certain substantiation requirements are satisfied.

- 3 - The issues for decision* are:- (1) Whether petitioners are entitled to a charitable contribution deduction under section 1701 of $263,933 for purported transfers of appreciated stocks and cash to the xélan Foundation; (2) whether petitioners must include in gross income $93,324 of capital gain resulting from the sales of the appreciated stocks- by the xélan Foundation in 1998 and $981 of interest and dividend income generated in 1998 by property purportedly t

1701 et seq., the National Emergencies Act, 50 U.S.C. sec. 1601 et seq., and 3 U.S.C. sec. 301, I, Jimmy Carter, President of the United States, find that the situation in Iran constitutes an unusual and extraordinary threat to the national security, foreign policy and economy of the United States and hereby declare a national emergency to dea