Anselmo v. Commissioner
United States Tax Court
P donated 461 colored gems to the Smithsonian Institution slightly more than 9 months after purchasing them. The amount claimed as a charitable contribution deduction was approximately 5 times the amount petitioner paid for the gems. Because jewelry stores did not sell unset gems like those held by P, P and his expert appraisers determined the value of the gems by reference to the prices charged by jewelry stores for individual items of jewelry.
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P donated 461 colored gems to the Smithsonian Institution slightly more than 9 months after purchasing them. The amount claimed as a charitable contribution deduction was approximately 5 times the amount petitioner paid for the gems. Because jewelry stores did not sell unset gems like those held by P, P and his expert appraisers determined the value of the gems by reference to the prices charged by jewelry stores for individual items of jewelry. The appraisals were based on their estimates of the portion of the retail price of jewelry containing gems like those held by P that would be…
1Opinion of the Court
Whitaker, Judge:
Respondent determined deficiencies in petitioners’ income tax for the calendar years 1977 and 1978 in the amounts of $12,874 and $19,207, respectively. The sole issue for our consideration is the fair market value of colored gems1 donated by petitioners to the Smithsonian Institution in 1977.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The parties have stipulated that Ronald P. Anselmo (hereinafter petitioner) and his wife Kay W. Anselmo resided in Fort Lauderdale, Fla., when the petition in this case was filed.
On their 1977 individual income tax…
2Cases cited13 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- Reiff v. CommissionerUnited States Tax Court · 1981
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Estate of Lang v. CommissionerUnited States Tax Court · 1975
- Estate of Smith v. CommissionerUnited States Tax Court · 1972
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3Cited by70 opinions
- Chiu v. CommissionerUnited States Tax Court · 1985
- Skripak v. CommissionerUnited States Tax Court · 1985
- Martin Ice Cream Co. v. Comm'rUnited States Tax Court · 1998
- IT&S of Iowa, Inc. v. CommissionerUnited States Tax Court · 1991
- Lio v. CommissionerUnited States Tax Court · 1985
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