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The Brand Archive
On August 13, 1983, petitioners bought Horace's half of the
coin ledgers, Horace's half of the photocopy, and a reverse
photocopy of the Chicago Coin Co. papers at a public auction for
$22,550. The coin ledgers, the photocopy, the Chicago Coin Co.
papers, the Virgil Brand estate papers, Armin's papers, the Jane
Allen papers, and various coin envelopes collectively constitute
the Brand Archive (Brand Archive).
The Contribution
Petitioners contributed the Brand Archive (the contribution)
to the American Numismatic Society on September 3, 1991 (the
contribution date). On their respective 1991 Federal income tax
returns, each of the children claimed a $58,333.33 charitable
contribution deduction on account of the contribution which
represented one-third of the claimed value of the Brand Archives
($175,000). Respondent determined that the fair market value of
the Brand Archive on the contribution date did not exceed $75,000
and disallowed each of the claimed deductions to the extent that
it exceeded $25,000.
Ultimate Finding of Fact
On the contribution date, the fair market value of the Brand
Archive was $142,650.
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