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Mark IV helmet at issue was worth approximately $400 to $500, and
he offered to purchase it for a price within that range.
About one to two years after his initial telephone conversa-
tion with Dr. Jamieson, petitioner telephoned Dr. Jamieson and
offered to sell him a Mercury helmet. Dr. Jamieson recognized
the caller's voice as that of petitioner, informed petitioner
that the helmet that he was offering for sale was a Mark IV
helmet and not a Mercury helmet, and advised petitioner that the
value of the helmet petitioner owned was approximately $400 to
$500.
About two months after his initial telephone conversation
with Mr. Gilliam, petitioner telephoned Mr. Gilliam. Upon
discovering that he had had a prior telephone conversation with
Mr. Gilliam, petitioner terminated that second telephone conver-
sation.
During 1991, petitioner donated the Mark IV helmet that he
had purchased in June 1977 to the Liberal Air Museum (museum) in
Liberal, Kansas. By letter dated June 23, 1992, Stephen G.
Brown, Executive Director of the museum, confirmed that that
helmet was in the possession of the museum.
In his 1991 Federal income tax return (1991 return), peti-
tioner, who had no expertise in personal property valuation,
valued the Mark IV helmet that he had donated to the museum at
$76,700 and claimed a charitable contribution deduction in the
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