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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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