The U.S. Tax Court ruled against Setty Gundanna and Prabhavathi Katta Viralam, denying their claimed charitable contribution deduction for transferring appreciated stocks to the xélan Foundation. The court found that the taxpayers retained control over the assets, as the foundation made student loans to their children and allowed family compensation for charitable services. The court also imposed a negligence penalty under IRC sec. 6662 for claiming the deduction without proper substantiation and for relying on promotional materials that were 'too good to be true.'
documents/EFTA00598056.pdf
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