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of unsold canned goods and other general merchandise. The amount
of petitioner's charitable deduction that relates to unsold
canned goods and other general merchandise is $85,040 for TYE
February 3, 1985 and $198,286 for TYE February 2, 1986.
For TYE February 3, 1985, petitioner concedes the charitable
deduction amount of $91,624 relating to its contributions from
its stores in Florida.
After these concessions, the only contributions at issue are
the 4-day-old bread and other "aged" bakery goods from
petitioner's California and Nevada stores. At the trial, the
parties focused almost entirely on the 4-day-old bread, so we
proceed upon the assumptions that the dollar amounts of the
donations of other bakery products were relatively insignificant,
and that our conclusion as to the value of the 4-day-old bread
will establish the method for valuing these items.
The parties also appear to agree that (1) after petitioner's
concession of the portions of its claimed deductions for the
Florida donations and the donations of canned goods and other
general merchandise, (2) after adjusting the cost basis for the
remaining contributed bakery inventory, and (3) after the
reduction required under section 170(e)(3)(B), the amounts of
charitable deductions in dispute are $663,855 for TYE February 3,
1985 and $1,300,558 for TYE February 2, 1986, based on the retail
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