T.C. Memo. 2006-63
UNITED STATES TAX COURT
IAN G. KOBLICK AND TONYA A. KOBLICK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13808-04. Filed April 3, 2006.
V. Jean Owens, for petitioners.
Timothy Maher, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: Petitioners Ian G. and Tonya A. Koblick
(individually referred to as Mr. Koblick and Mrs. Koblick,
respectively) challenge respondent’s income tax deficiency
determination for 1998 and 1999 which is based upon the
disallowance of charitable deductions that were carried forward
from a 1994 contribution of 45 percent of the outstanding stock
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1Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
in Sealodge International, Inc. (Sealodge) to Maine Resources
Development Foundation (MRDF), a section 501(c)(3)1 charity. The
issue before us is the value of the 45-percent stock ownership
interest in Sealodge. As explained in more detail herein, we
find that the interest was worth significantly less than reported
FINDINGS OF FACT
Petitioners are husband and wife who resided in Key Largo,
Florida, as of the date of the filing of the petition.
On December 19, 1994, Mr. Koblick transferred 11,247 shares
of common stock of Sealodge to MRDF. The 11,247 shares of
Sealodge stock transferred by Mr. Koblick to MRDF represented 45
percent of the outstanding stock of Sealodge. There were two
other shareholders of Sealodge, Dr. Neil Monney (Dr. Monney), who
owned 45 percent, and Debra Alexander, who owned 10 percent.
They also transferred their shares to MRDF simultaneously with
Mr. Koblick’s transfer.
Petitioners received $90,000 from MRDF in exchange for the
45-percent interest in Sealodge transferred to MRDF by Mr.
Koblick. On their 1994 Form 1040, U.S. Individual Income Tax
Return (Form 1040), petitioners claimed that the fair market
value of the stock in Sealodge donated