- 2 -
Addition
to Tax
Year Deficiency Sec. 6659
1985 $5,061 $1,518
1986 6,783 2,035
1987 6,287 1,886
1988 6,118 1,835
The issues for decision are: (1) The fair market value of
the movie memorabilia (the collection) donated by Gerald
Leibowitz (petitioner) to the American Museum of the Moving Image
(AMMI) for purposes of determining the charitable contribution
deductions to which petitioners were entitled for 1985, the year
of the gift, and for the later years by way of carryovers; and
(2) whether petitioners are liable for additions to tax under
section 66591 for a valuation overstatement.
We find the value of the collection to be less than
petitioners claimed, but more than respondent allowed, which will
result in deficiencies for 1987 and 1988. We hold that
petitioners are not liable for additions to tax for a valuation
overstatement.
FINDINGS OF FACT
1 Unless otherwise identified, section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011