- 7 - amount of $19,795.2 Attached to petitioner's 1991 return was a report (Hetz report) that contains what purports to be the signa- ture of Russell W. Hetz (Mr. Hetz).3 The Hetz report indicated that, based on the cost approach, "We recommend a Rounded Es- timate [sic] Fair Market Value" for "the MARK IV United States Navy Helmet, Circa 1959" of $76,700.4 2 Petitioner calculated the amount of the deduction reported in his 1991 return on the basis of the claimed fair market value of the Mark IV helmet at issue, reduced to take account of the limitation prescribed in sec. 170(b)(1)(A) that the deduction not exceed 50 percent of his contribution base for 1991. 3 Mr. Hetz' purported resume states, inter alia, that he is "a Fee Appraiser, specializing in the market valuation of industrial machinery and transportation equipment." 4 The Hetz report noted, inter alia, that the various factors to be considered in determining that value included the "Sale of [a] similar Helmet." That report further stated, with no explana- tion: "WE have elected to use the Cost Approach." It described the cost approach as an estimate of "value based on the current cost in dollars of a new replacement Property Unit of similar design, capacity, materials and utility." The Hetz report concluded that the total design and material cost of "the MARK IV Pressure Helmet" as of the time the Hetz report was prepared was $338,000. It then allocated that cost to the Mark IV helmet that was the subject of the Hetz report as follows: In order to spread the development costs for High Technol- ogy Projects such as this MARK IV Helmet, the first 2 units produced are tested to their limits, usually to destruc- tion. We say the subject Helmet was the first one built after the tests and we shall spread the Design and Material Cost over the First Three Units. 3 $338,000 = $112,933 [sic] Allocated Cost for the Subject Helmet. The Hetz report adjusted that $112,933 allocated cost for depreciation using a 100-year useful life for the helmet that was the subject of that report and arrived at a recommended "Rounded Estimate [sic] Fair Market Value" of $76,700 for that helmet.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011