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SPECIAL GIFT SITUATIONScharitable deduction for that amount only. (As noted, the donors purchasedthe books for one-third of the list price.) 6• Individuals purchased a substantial number of unframed lithographs,held them for the long-term capital gain treatment period, then donatedthem to charitable organizations. The court valued the lithographs on thebasis of the market in which the donors purchased them, not “on theprices paid in only a few sales.” 7• An individual was denied an income tax charitable deduction in excess ofthe amount allowed by the IRS for artwork and copyrights contributed toa museum. The court essentially rejected the opinions of the expert witnesseson both sides of the case. 8• An individual purchased a substantial number of Indian artifacts andetchings, held them for the requisite capital gain holding period, and thendonated most of them to a museum. The court found that the donateditems were grossly overvalued and that there was a pattern of abusedesigned to achieve excessive valuations of the items. The value assertedby the IRS was found to be the appropriate value. 9• Individuals contributed African art objects to a charitable organization.The court substantially reduced the value of the items in relation to theamount claimed by the donors, finding that most of the artwork was not“traditional” African art but “tourist” or “airport” art. 10• Individuals contributed art objects to a museum and claimed charitablecontribution deductions based on appraisals. The IRS contested theclaimed charitable deduction. The court upheld the donor’s value in full. 11• An individual contributed a statue to a state. The donor claimed a valueof $800,000. The IRS asserted that the value was $50,000. The court foundthe value to be $600,000, concluding that the donor’s expert witness wasmore persuasive than the witness provided by the government. 12• A court found that charitable contribution deductions claimed for gifts ofartwork to colleges were deliberately inflated and were tax-motivatedtransactions. 13• A court denied charitable deductions claimed for gifts of paintings andsculptures to museums because of valuation overstatements. The courtbased its valuations on expert testimony. 146 Skripak v. Commissioner, 84 T.C. 285 (1985).7 Lio v. Commissioner, 85 T.C. 56, 71 (1985), aff’d sub. nom. Orth v. Commissioner, 813 F.2d 837 (7th Cir.1987).8 Harken v. Commissioner, 50 T.C.M. (CCH) 994 (1985).9 Johnson v. Commissioner, 85 T.C. 469 (1985).10 Neely v. Commissioner, 85 T.C. 934 (1985).11 Biagiotti v. Commissioner, 52 T.C.M. (CCH) 588 (1986).12 Koftinow v. Commissioner, 52 T.C. 261 (1986).13 Angell v. Commissioner, 52 T.C.M. (CCH) 939 (1986).14 Frates v. Commissioner, 53 T.C.M. (CCH) 96 (1987). 270

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