Chiu v. Commissioner
United States Tax Court
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
Cohen, Judge-.
Respondent determined deficiencies in petitioners’ Federal income taxes as follows:
Year Deficiency
1978 . $20,508.17
1979 . 46,429.93
1980 ..-. 36,550.00
In dispute is the value of certain gemstones and mineral specimens donated by petitioners to the Smithsonian Institution.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulation is incorporated herein by this reference. Petitioners were residents of Columbus, Ohio, at the time they filed their petition herein. They filed joint Federal income tax returns for the taxable years 1978,1979, and 1980 with the…
2Cases cited22 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
17 more not listed; retrieve them via the Exa API.
3Cited by184 opinions
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Beck v. CommissionerUnited States Tax Court · 1985
- Parker v. CommissionerUnited States Tax Court · 1986
- Rose v. CommissionerUnited States Tax Court · 1987
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
179 more not listed; retrieve them via the Exa API.