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represented that he purchased the Kesslers on June 1, 1976, at a
cost of $135,065. He stated “various” as the acquisition date of
each of the religious items and did not state a cost for any of
them. Petitioner listed the fair market values of the
contributed property on Form 8283 as follows:
Claimed Fair
Item Market Value
Kesslers $900,430
Biblical books 18,600
St. Peter painting 15,000
Madonna painting 5,000
Monstrance 10,000
Total $949,030
No appraisal was attached to petitioner’s 1993 or 1994 Federal
income tax returns substantiating the fair market values claimed
by petitioner. The charitable contribution deduction claimed for
1993 was limited to $476,700, with the remaining $486,327
attributable to noncash items being carried forward and deducted
on the 1994 Federal income tax return.
In the statutory notice, respondent allowed only $12,973 as
the fair market value of the donated noncash property. Thus,
respondent disallowed $449,730 of petitioner’s charitable
contributions for 1993 and all of the $486,327 charitable
contribution carryover for 1994.
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Last modified: May 25, 2011