- 54 - received was not confined to the cash payment for their tangible assets. They in addition received a package of valuable benefits (above-median compensation, $35,000 "Physician Access Bonuses", working conditions they preferred, etc.) that were not merely incidental or akin to the benefits that inure to the general public as a result of a charitable transfer. See, e.g., Ottawa Silica Co. v. United States, 699 F.2d 1124 (Fed. Cir. 1983); Singer Co. v. United States, 196 Ct. Cl. 90, 449 F.2d 413 (1971). Concededly, some elements of the consideration petitioners received may have been difficult to quantify, but this does not mean these benefits can be disregarded in determining whether a quid pro quo existed that defeats donative intent. See, e.g., Transamerica Corp. v. United States, 902 F.2d 1540 (Fed. Cir. 1990) (donor-taxpayer's receipt back from donee of commercial access rights to donated motion picture film negatives defeats charitable deduction for value of negatives transferred); Singer Co. v. United States, supra (benefit of possible increase in future customers defeats charitable deduction for the value of discounts given to public schools purchasing taxpayer's sewing machines). Petitioners argue that any consideration they purportedly received in the transaction representing the "value of their post- contribution employment relationship" with SMF must be disregarded because "that value is already taken into consideration in thePage: Previous 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 NextLast modified: March 27, 2008