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OTHER ASPECTS OF DEDUCTIBLE GIVINGCustoms Service for import duty purposes), whereas the court held thatthe fair market value was $67,500. 63• In the absence of evidence presented by the donors as to the value of conferencematerials they donated to a charitable organization, the charitablecontribution deduction was determined to be $10,000, rather than theclaimed $39,130. 64• An open-space conservation easement was valued on the basis of its mostprofitable use (a duck hunting club), using the “before and after” method. 65• The fair market value of silver coins, a silver bar, and a copper ingot contributedto a museum was determined. 66• The fair market value of a collection of sheet music, contributed to a charitableorganization over a three-year period, was determined not to be inexcess of the amount represented by the donor’s claimed deductions forthose years ($96,616); thus, the claimed charitable deductions (total of$340,000) for amounts carried forward into the three subsequent yearswere disallowed. 67• The fair market value of an interest in an oil and gas partnership (aburned-out tax shelter) was held not to be in excess of the amount representedby the donors’ claimed deductions for a period of years ($61,955),so carryover deductions were disallowed (total claimed deduction was$108,000). The donors were faulted for not offering any comparative oractual selling prices for the partnership interests; the court wrote that itwas unwilling to rely on a “purely theoretical” estimate of value. 68• A court refused to allow valuation of charitable gift property beyond thatclaimed over four years; hence, carryover deductions were disallowed. 69• A court concluded that an individual was entitled to a charitable contributiondeduction of $500 for a gift of a flight helmet to a museum. 70• In a case involving valuation of stock in a closely held corporationdonated to a university, a court applied the adjusted net worth method.The claimed deduction was $260,000; the fair market value of the propertyfound by the court was $63,885. 71• An owner donated unproductive mining property to the federal governmentand claimed a charitable contribution deduction in the amount of$2.75 million; a court concluded that the actual value was $38,000. The63 Pasqualini v. Commissioner, 103 T.C. 1 (1994).64 Osborne v. Commissioner, 68 T.C.M. (CCH) 273 (1994).65 Schwab v. Commissioner, 67 T.C.M. (CCH) 3004 (1994).66 Ferman v. Commissioner, 68 T.C.M. (CCH) 1063 (1994).67 Rimmer v. Commissioner, 69 T.C.M. (CCH) 2620 (1995).68 Harding v. Commissioner, 69 T.C.M. (CCH) 2625, 2629 (1995).69 Manning v. Commissioner, 70 T.C.M. (CCH) 490 (1995).70 Droz v. Commissioner, 71 T.C.M. (CCH) 2204 (1996).71 Krapf, Jr. v. United States, 96-1 U.S.T.C. 50,249 (Fed. Cl. 1996). In an earlier opinion, the court placed thevalue at $112,840. Krapf, Jr. v. United States, 89-2 U.S.T.C. 9448 (1989), rev’d & remanded, 977 F.2d 1454(Fed. Cir. 1992). 362