- 7 - two appraisers whom it hired both valued the parcel at about $2.7 million. The Wilkersons were a bit skeptical, and talked with several people in the business before they had Terrene claim such a large deduction. Having convinced themselves that the appraisals were correct, they had Terrene donate the parcel to the Assemblies of God Foundation in November 1998, and claim a $2.7 million charitable contribution deduction on its 1998 partnership return. Their initial skepticism was justified when the return was chosen for audit. The Commissioner determined that the fair-market value of the donated land was only $150,000, and he mailed Terrene a notice of Final Partnership Administrative Adjustment (FPAA). Terrene timely filed its petition, and the case was tried in Houston on the valuation question alone. Discussion The question before us is really a question of just what effect the four holes drilled into the 31.41-acre parcel of the Hamblen Road property had on its value. Under section 170, the amount of the deduction for a contribution of property to a charity is its fair-market value (FMV) at the time of donation. Sec. 1.170A-1(c)(1), Income Tax Regs. The regulations define FMV as “the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007