Bruce and Jeanne Korson, et al. - Page 6

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                                       OPINION                                        
          I.  Introduction                                                            
               These consolidated cases involve income tax deductions                 
          claimed on account of charitable contributions.  The particular             
          question before us is the value of certain numismatic materials             
          (the Brand Archive) contributed to the American Numismatic                  
          Society on September 3, 1991.  Petitioners claim that the fair              
          market value of the Brand Archive on the contribution date was              
          $605,000, while respondent claims that its fair market value did            
          not exceed $75,000.  Value is a question of fact, and petitioners           
          bear the burden of proof.  Rule 142(a).  We have found that the             
          fair market value of the Brand Archive on the contribution date             
          was $142,650.                                                               
          II.  Code and Regulations                                                   
               Section 170(a)(1) allows a deduction for any contribution              
          made to a qualified donee organization.  It is undisputed that              
          the American Numismatic Society is a qualified donee                        
          organization, and the only question before the Court is the                 
          amount of the contribution on the contribution date.  The parties           
          agree that each of the children was entitled to deduct one-third            
          of the fair market value of the Brand Archive on the contribution           
          date.  With exceptions not here relevant, if a charitable                   
          contribution is made in property other than money, the amount of            
          the contribution is the fair market value of the property at the            
          time of the contribution.  Sec. 1.170A-1(c)(1), Income Tax Regs.            



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