Mohamed v. Commissioner
United States Tax Court
T.C. Memo 2012-152 (2012)
- Written by Kelsey Libby, JD
Facts
In 2003, Joseph and Shirley Mohamed (plaintiffs) donated five properties to a trust they had previously established for the benefit of several charitable organizations. On the Mohameds’ 2003 tax return, Joseph himself completed Form 8283 for noncash charitable contributions. Joseph did not read the separate instructions, and the form itself did not state that an appraisal needed to be attached. Joseph listed the value of the five properties as approximately $15.8 million. In April 2005, the commissioner of internal revenue (defendant) began an audit of the Mohameds’ 2003 tax return. The Mohameds then hired an independent auditor to appraise the five properties, and the valuation came back at approximately $17.3 million total. Although the Mohameds had undervalued the properties, the commissioner took the position that the charitable deductions must be denied in their entirety due to mistakes on the Mohameds’ Form 8283. Thus, the commissioner moved for summary judgment in the tax court.
Rule of Law
Issue
Holding and Reasoning (Holmes, J.)
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