Case: Factual Issues Remain in Charitable Contribution Deductions Case, Summary Judgment Denied (T.C.) (IRC §170)

Factual issues exist regarding substantiation requirements and application of the reasonable cause defense related to charitable contribution deductions claimed for donations of artifacts to a museum, the U.S. Tax Court held, denying cross-motions for partial summary judgment. Taxpayers, several individuals and trusts that own shares in an S corporation, claimed charitable contribution deductions on their tax returns for the S corporation’s noncash donations of biblical artifacts to a museum. The IRS disallowed the deductions, arguing Taxpayers failed to properly substantiate the donations. The court held that whether Taxpayers had reasonable cause for any substantiation failures was a factual issue requiring ...