-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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011