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to the county, the tax-free nature of the interest on the
county’s debt, and the value of the charitable contribution
deduction all must be subtracted from the fair market value of
the easement in determining the amount of any gift to the county.
Respondent is mistaken. As stated, supra sec. IV.A., the
gift portion of a bargain sale is measured by the difference
between the fair market value of the property and the amount
realized from the sale. The tax consequences described are not
part of the amount realized. See sec. 1001(b). Respondent’s
argument suggests that a taxpayer making a gift of stock worth
$100 to a charitable organization may be entitled to a charitable
contribution deduction of some lesser amount on account of the
economic value of the deduction. That suggestion is untenable.
The regulations provide explicitly that, if a charitable
contribution is made in property, the amount of the contribution
is the fair market value of the property. Sec. 1.170A-1(c)(1),
Income Tax Regs.
Respondent's reliance on DeJong v. Commissioner, 36 T.C. 896
(1961), affd. 309 F.2d 373 (9th Cir. 1962), is misplaced. In
DeJong, this Court found that a portion of the claimed charitable
contribution was made in anticipation of the charitable
organization providing “free” schooling to the taxpayers'
children. The cost of that education reduced the amount of the
charitable contribution. In this case, Howard County and
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