- 10 -
those items. We recognize that the determination of the fair
market value of an item involves an approximation, and is, at
best, an inexact science. Stanley Works v. Commissioner, 87 T.C.
389, 407-408 (1986); see Colonial Fabrics v. Commissioner, 202
F.2d 105, 107 (2d Cir. 1953); Goldstein v. Commissioner, 89 T.C.
535, 544 (1987); Skripak v. Commissioner, 84 T.C. 285, 320
(1985); Zmuda v. Commissioner, 79 T.C. 714, 726 (1982), affd. 731
F.2d 1417 (9th Cir. 1984); Estate of DeBie v. Commissioner, 56
T.C. 876, 894 (1971); see also Cooley v. Commissioner, 33 T.C.
223, 225 (1959), affd. 283 F.2d 945 (2d Cir. 1960). However, we
cannot ignore that, more often than not, personal items, like
used clothing and household items, will be worth far less than
their original purchase price immediately after they are
purchased. Furthermore, as best we can determine from
petitioner’s testimony, the original costs of the donated items
shown on the Forms 8283 are themselves not actual costs, but only
estimates based upon petitioner’s optimistic estimates of the
items’ fair market values.14
We cannot accept petitioner’s fair market value estimates of
the property that form the basis for a portion of the charitable
14 Petitioner testified that she first determined the fair
market value of an item and then assumed that the cost of the
item was at least twice as much.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011