Legal Opinion

Chiu v. Commissioner

United States Tax Court

Decided April 15, 1985No. Docket No. 14166-83Published

Petitioners purchased gemstones and minerals in the years 1977, 1978, and 1979, and approximately 1 year after the dates of purchase donated them to the Smithsonian Institution. Held, the most reliable evidence of the fair market value of the items was the cost of the items to the petitioners.

1Opinion of the Court

Robert C. Chiu and Carol A. Chiu, Petitioners v. Commissioner of Internal Revenue, Respondent

Chiu v. Commissioner

Docket No. 14166-83

United States Tax Court

84 T.C. 722; 1985 U.S. Tax Ct. LEXIS 93; 84 T.C. No. 48;

April 15, 1985. April 15, 1985, Filed

Decision will be entered for the respondent.

Petitioners purchased gemstones and minerals in the years 1977, 1978, and 1979, and approximately 1 year after the dates of purchase donated them to the Smithsonian Institution. Held, the most reliable evidence of the fair market value of the items was the cost of the items to the petitioners.

Ronald W.…

2Cases cited23 opinions

  1. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  2. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  3. Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
  4. Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
  5. Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957

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