Estate of Palmer v. Commissioner
United States Tax Court
Decedent donated certain land and improvements located in Davenport, Iowa, to the Palmer College Foundation. Held, reproduction cost of the improvements vastly exceeds fair market value; fair market value of the contributed property is determined. Sec. 170(a)(1), I.R.C. 1954.
1Opinion of the Court
CHABOT, Judge:
Respondent determined deficiencies in Federal individual income tax against petitioners as follows:
Year Deficiency
1971. $41,865.79
1972 . 76,171.10
1973 . 25,992.78
Petitioners claim an overpayment for 1973 in the amount of $30,000, or such greater amount as they may be entitled to.1 The issue for decision is the fair market value, as of August 25, 1971, of certain improved real property that was contributed to an eligible charitable donee.
FINDINGS OF FACT
Some of the facts have been stipulated, the stipulations and the stipulated exhibits are incorporated herein by this reference.
Wh…
2Cases cited8 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Kaplan v. CommissionerUnited States Tax Court · 1965
- Palmer v. CommissionerUnited States Tax Court · 1974
- Daniel D. And Agnes H. Palmer v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1975
3 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Estate of D.D. Palmer, Deceased, Richard L. Braunstein and Davenport Bank & Trust Co., Executors and A.H. Palmer v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1988
- Rolfs v. Comm'rUnited States Tax Court · 2010
- Whitehouse Hotel Ltd. P'ship v. Comm'rUnited States Tax Court · 2012
- William H. Cosby, Jr., and Camille O. Cosby v. The United States, Jack Barry Productions, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1986
- Epping v. CommissionerUnited States Tax Court · 1992
10 more not listed; retrieve them via the Exa API.