W%: Tax Court Rapiers (Current). Sony Canaan'', and Pratthavatla Karla Wag am v. Commisseanat. U.S. Tax Cowl. CCH Dec. 64644 136 T.C. M18. ria Tax Court Regulars (Current), Setty Gundanna and Prabhavathi Katta Viralam v. Commissioner., U.S. Tax Court, CCH Dec. 58,547, 136 T.C. No. 8, (Feb. 14, 2011) Slick to open document in a browser Setty Gundanna and Prabhavathi Katta Viralam v. Commissioner. U.S. Tax Court, Dkt. No. 21355-03, 136 TC —, No. 8, February 14, 2011. [Appealable, barring stipulation to the contrary, to CA-11.—CCH.) [ Code Sec. 170) Donor advised foundation: Charitable contribution: Dominion and control: Substantiation.— A taxpayer who transferred appreciated stock to his newly established donor advised foundation failed to make a charitable contribution, and hence could not deduct the contribution or avoid paying tax on the subsequent sale of the stock by the foundation. The taxpayer did not relinquish dominion and control over the assets because he made the transfer with the expectation that the foundation would make educational loans to his children, which the foundation in fact did. He also understood that the foundation would allow members of his family to earn compensation by performing unspecified charitable services for the foundation. In addition, the transfer failed as a contribution due to a lack of substantiation because the foundation failed to acknowledge in writing that the taxpayer would receive goods and services (i.e., the student loans) in exchange for the contribution.—CCH. [ Code Seer 6662) Negligence penalty: Charitable contribution: Reliance on tax advisor.— A negligence penalty was imposed on a taxpayer for claiming as a charitable contribution the transfer of appreciated stock to a donor advised foundation with the understanding it would provide student loans to his children (which it in fact did), and provide compensation to family members for doing charitable services. The taxpayer was liable for the pen