-2-
Petitioners 1999 Deficiency 2000 Deficiency
Wortmann $12,864 $12,536
Cain 13,712 10,193
Archbold 18,655 11,347
Hesse 15,530 14,431
We are asked to decide the fair market value of land near
Oakdale, Nebraska, improved with a chapel, monastery, and
dormitory (the retreat center) for purposes of determining the
amount of the allowable charitable contribution deduction under
section 170.2 Petitioners determined that the retreat center had
a value of $475,0003 at the time of contribution, and deducted
charitable contributions accordingly. Respondent determined that
the retreat center had a value of $76,200 at the time of
contribution. We hold that the fair market value of the retreat
center at the time of contribution was $76,200.
2All section references are to the Internal Revenue Code in
effect for the years at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
3Of the $551,272 total charitable contribution deductions
petitioners claimed on their respective tax returns, respondent
does not dispute $76,082, representing the value of the personal
property within the buildings of the retreat center. The parties
stipulated that $475,000 was at issue, which is also the value of
the retreat center property determined by petitioner’s expert.
We assume this to be an approximation of the $475,190 result of
subtracting the agreed valuation of the personal property from
the total charitable contribution deductions. Petitioners’
deductions of $76,082 attributable to the personal property
within the buildings are therefore not at issue. We focus solely
on the real estate value of the retreat center.
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