Bennett v. Commissioner
United States Tax Court
P contributed 236 films to a charitable organization. In accord with an appraisal, P placed a $<>236,000 value on the films. R, in the process of examining P's contributions, had X, an in-house engineer, value the films. X opined that the films had no (zero) value. R then hired Y, an outside "independent" expert, to value the films. Finally, R had Z, another in-house engineer, value the films. Z opined that 118 of the 236 films were damaged and were of no value.
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P contributed 236 films to a charitable organization. In accord with an appraisal, P placed a $<>236,000 value on the films. R, in the process of examining P's contributions, had X, an in-house engineer, value the films. X opined that the films had no (zero) value. R then hired Y, an outside "independent" expert, to value the films. Finally, R had Z, another in-house engineer, value the films. Z opined that 118 of the 236 films were damaged and were of no value. Z also opined that P had correctly valued at $<>1,000 per film those of the films that were not damaged. R's notice of deficiency to…
1Opinion of the Court
RICHARD L. BENNETT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bennett v. Commissioner
Tax Ct. Dkt. No. 19775-96
United States Tax Court
T.C. Memo 1997-505; 1997 Tax Ct. Memo LEXIS 591; 74 T.C.M. (CCH) 1144;
November 10, 1997, Filed
P contributed 236 films to a charitable organization. In accord with an appraisal, P placed a $236,000 value on the films. R, in the process of examining P's contributions, had X, an in-house engineer, value the films. X opined that the films had no (zero) value. R then hired Y, an outside "independent" expert, to value the films. Finally, R had Z,…
2Cases cited19 opinions
- Hickman v. TaylorSupreme Court of the United States · 1947
- United States v. Procter & Gamble Co.Supreme Court of the United States · 1958
- Coastal States Gas Corporation v. Department of EnergyCourt of Appeals for the D.C. Circuit · 1980
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- United States v. BaggotSupreme Court of the United States · 1983
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3Cited by1 opinion
- Deseret Management Corp. v. United StatesUnited States Court of Federal Claims · 2007