Benjamin H. and Diane E. Robson - Page 3

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          (1) The fair market value of various wild game animal trophy                
          mounts donated by petitioners; and (2) whether certain appraisal            
          fees are deductible.                                                        
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are incorpo-             
          rated herein by this reference.  Petitioners resided in Whittier,           
          California, at the time their petitions were filed.                         
               During the years at issue, Dr. Benjamin H. Robson (peti-               
          tioner Robson) and Dr. Leroy C. Trnavsky (petitioner Trnavsky)              
          were orthodontists.  Both petitioner Robson and petitioner                  
          Trnavsky are accomplished hunters.  They have been on numerous              
          hunting trips to locations around the world and have acquired               
          various animal mounts over the course of many years of hunting.             
          Petitioners maintained the animal mounts in trophy rooms at their           
          respective homes.                                                           
               Over the 3-year period from 1990 to 1992, petitioner Robson            
          donated 30 animal specimens, including shoulder mounts and capes            
          and horns, to various charitable organizations.  Petitioner Rob-            
          son claimed deductions for charitable contributions of $53,600,             
          $67,100, and $61,300 for tax years 1990, 1991, and 1992, respec-            
          tively.  During this same period, petitioner Trnavsky donated 24            
          animal specimens to various charitable organizations and claimed            
          deductions for charitable contributions of $39,500, $34,400, and            
          $41,150 for tax years 1990, 1991, and 1992, respectively.                   




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