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Mr. Griffith updated his appraisal of the land for
petitioners on February 27, 1991, and concluded that the fair
market value of the land as of December 1, 1990, remained
$771,600. In accordance with Mr. Griffith’s appraisal of the
easement at $598,500, petitioners claimed a charitable
contribution of $289,500 during 1990, which is the difference
between the appraised value of $598,500 and the $309,000 received
for the easement from Howard County. Because of annual
limitations on the amount of the deduction that may be claimed by
an individual on account of charitable contributions, petitioners
claimed deductions on account of the conveyance of the easement
to the county as follows:
1990 $52,194
1991 23,813
1992 51,645
1993 44,895
Total $172,547
Respondent disallowed those deductions on the grounds that
petitioners had failed to substantiate the charitable
contribution resulting from the conveyance of the easement.
Expert Testimony
Petitioners’ Experts
Stanley O. Benning
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