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($100 membership fee plus $537.50 mileage deduction equals
$637.50 plus $50 donation, per petitioner’s testimony, equals
$687.50 concession).
Petitioner testified that in 1999 he donated an antique
medicine bag (bag) to the DMNH. Petitioner valued the bag at
$960 and claimed a deduction for a gift to charity of $960 other
than by cash or check on his 1999 return. On his 1999 return,
petitioner stated that he inherited the bag in 1987 and that the
donor’s cost or adjusted basis in the bag was zero dollars.
Petitioner attached to his 1999 return an “inspection
request” he had submitted on November 29, 1998, to the DMNH.
Petitioner stated the item to be valued was a “Medicine Bag”.
Petitioner estimated the value of the bag to be “$101-$500”.
Petitioner wrote: “Requester may donate bag to DMNH if can be
displayed.” (Emphasis added.)
On May 24, 1999, Joyce Herold, Curator of Ethnology,
Department of Anthropology, noted on the inspection request that
the bag was “probably of Jicarilla Apache origin” and dated the
bag circa 1890. In a separate memorandum dated May 24, 1999, Ms.
Herold advised petitioner: “If you want to donate the pouch, we
would be delighted. * * * You can take as an IRS charitable
deduction the full appraised value of the piece. However, the
promise of exhibition is not possible, * * * . Thanks for leaving
the piece for my inspection”. (Emphasis added.)
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