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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.
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