Hearst Corp. v. United States

OPINION

HARKINS, Senior Judge:

The Hearst Corporation, plaintiff, seeks a refund of income tax for tax years 1981 through 1985 based upon a charitable contribution to the University of California at Los Angeles, California (UCLA) of the Hearst Metrotone News Film Library (Library). Hearst documented the donation by letters dated November 30, 1981, March 5, 1982, February 1, 1985, and November 18, 1985; UCLA’s acceptance of the Library is documented by letters dated December 2, 1981, March 8, 1982, February 5, 1985, and November 19, 1985.

In its tax returns for the relevant years, Hearst reported…