Charitable Deduction Denied

In Evenchik v. Commissioner, T.C. Memo. 2013-34 (Feb. 4, 2013), the taxpayers donated approximately 72 percent of their shares in a corporation called Chateau Apartments, Inc., to a non-profit housing organization.  Chateau’s sole assets were two apartment buildings located in Arizona.  The taxpayers obtained appraisals of Chateau’s underlying assets and, based on these appraisals, claimed a charitable deduction under Internal Revenue Code Section 170 in 2004.  ...