- 6 - OPINION I. Introduction These consolidated cases involve income tax deductions claimed on account of charitable contributions. The particular question before us is the value of certain numismatic materials (the Brand Archive) contributed to the American Numismatic Society on September 3, 1991. Petitioners claim that the fair market value of the Brand Archive on the contribution date was $605,000, while respondent claims that its fair market value did not exceed $75,000. Value is a question of fact, and petitioners bear the burden of proof. Rule 142(a). We have found that the fair market value of the Brand Archive on the contribution date was $142,650. II. Code and Regulations Section 170(a)(1) allows a deduction for any contribution made to a qualified donee organization. It is undisputed that the American Numismatic Society is a qualified donee organization, and the only question before the Court is the amount of the contribution on the contribution date. The parties agree that each of the children was entitled to deduct one-third of the fair market value of the Brand Archive on the contribution date. With exceptions not here relevant, if a charitable contribution is made in property other than money, the amount of the contribution is the fair market value of the property at the time of the contribution. Sec. 1.170A-1(c)(1), Income Tax Regs.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011