Contents

§ 10.1 VALUATION OF PROPERTY• Two donors engaged in a bargain sale transaction 52 involving a boat witha charitable organization. They claimed a value of $169,000; the court,from the bench, ruled that the value was $160,000. 53• A donor contributed several wild game trophy mounts and rugs to amuseum, claiming a value of $126,500. The IRS contended that the itemslacked any value whatsoever; the court placed a value of $75,000 onthem. 54• In a case involving charitable gifts of interests in oil and gas leases, thedonors claimed charitable contribution deductions totalling $667,420;the IRS asserted a value of $138,000; the court found the value (and thusthe deduction) to be $534,144. 55• The fair market value of an open-space easement, contributed to a charitableorganization, was calculated using the difference in value of theproperty before and after the easement was granted. 56• The fair market value of a water tower donated to a city was determined. 57• The fair market value of a minority interest in common stock of a closelyheld corporation was determined, with an appellate court holding thatthe lower court relied on the wrong postgift transaction in valuing thestock. 58• The fair market value of shares of closely held stock, contributed bymeans of remainder interests in trust, was determined. 59• The fair market value of a yacht hull contributed to a charitable organizationwas determined; the claimed deduction was $145,000, whereas theallowed deduction was $45,000. 60• The fair market value of a painting donated to a museum was determined. 61• The fair market value of a sailboat donated to a charitable organizationwas determined. 62• The fair market value of 180,000 Christmas cards with gold medallionsdonated to a religious organization was ascertained; the donors used thefair market value of $1.89 million (based on value selected by the U.S.52 See § 9.19.53 Fair v. Commissioner, 66 T.C.M. (CCH) 460 (1993). Subsequently, the donors attempted to obtain an awardof litigation costs (under IRC § 7430) but failed, on the ground that the IRS’s position was not unreasonablebecause it was based on the testimony of an expert. Fair v. Commissioner, 68 T.C.M. (CCH) 1371 (1994).54 Engel v. Commissioner, 66 T.C.M. (CCH) 378 (1993).55 Haught v. Commissioner, 65 T.C.M. (CCH) 1921 (1993).56 Dennis v. United States, 92-2 U.S.T.C. 50,498 (E.D. Va. 1992).57 Brigham v. Commissioner, 64 T.C.M. (CCH) 244 (1992).58 Krapf v. United States, 977 F.2d 1454 (Fed. Cir. 1992).59 O’Reilly v. Commissioner, 95 T.C. 646 (1990), rev’d & remanded, 973 F.2d 1403 (8th Cir. 1992), on remand,67 T.C.M. (CCH) 2176 (1994).60 Bragg v. Commissioner, 66 T.C.M. (CCH) 1047 (1993).61 Doherty v. Commissioner, 63 T.C.M. (CCH) 2112 (1992), aff’d, 16 F.3d 338 (9th Cir. 1994).62 Parks v. Commissioner, 67 T.C.M. (CCH) 1911 (1994). 361