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the taxable year 1981; and (3) the fair market value on the date
of contribution of 24 boxes of gemstones donated by Mr. Hemmings
to the Gospel Fellowship Association in 1984.
Background
Mr. Brown is the father of Mrs. Hemmings and at one time was
the sole owner of Brown Transport Corp. (Brown Transport), a
trucking company. Mrs. Hemmings, a former school teacher,
obtained a B.A. in education from Emory University and a master's
degree in early childhood education. Mrs. Hemmings married Mr.
Hemmings in 1974, at which time she resigned from teaching and
afterwards devoted her time to being a mother and housewife.
After service with the U.S. Marine Corps, Mr. Hemmings
performed various jobs in the trucking industry, including
loading and driving trucks. He attended Woodrow Wilson Law
College at night. Mr. Hemmings graduated in 1959 and soon
thereafter obtained employment at Brown Transport. He never
practiced law or passed the bar. Around 1968, Mr. Hemmings
became president and chief executive officer of Brown Transport.
Through the years, Mr. Hemmings incrementally purchased
stock in Brown Transport. Brown Transport grew rapidly and the
Hemmingses profited as a result. By 1978 the Hemmingses
collectively owned assets worth in excess of $30 million,
including a
30-percent interest in Brown Transport valued at $20 million,
truck stops, residences, an airplane, a boat, and an ownership
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