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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 the
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