Case: Under Michigan Law, Valid Gift of Closely Held Appreciated Stock Made to Fidelity Charitable Donor-Advised Fund Occurred When Fund Received Stock Certificates, Not Date of Contribution Confirmation Letter (T.C. Memo) (IRC §501)

Petitioner (individual who owned a family business with his brothers): (1) made a valid gift of appreciated shares of stock in a closely held corporation to a charitable organization (Fidelity Charitable Gift Fund) that administers donor-advised funds for tax-exempt purposes under I.R.C. §501(c)(3) on July 13, 2015 (under Michigan law, when Fidelity first received a stock certificate from Petitioner’s representatives, not the date of Fidelity’s contribution confirmation letter, June 11, 2015); (2) realized and recognized gain pursuant to the anticipatory assignment of income doctrine because his right to proceeds from the sale became fixed before the gift because his ...