Symington v. Commissioner
United States Tax Court
Petitioners made a gift of an open-space easement to the Virginia Outdoors Foundation. Held, the value of the gift for purposes of a charitable deduction is determined on the basis of before-gift and after-gift valuations of the property subjected to the easement. Held, further, the approach to valuation cases set forth in Buffalo Tool & Die Mfg. Co. v. Commissioner, 74 T.C. 441, 451 (1980), is reiterated.
1Opinion of the Court
OPINION
TANNENWALD, Judge:
Respondent determined a deficiency of $24,547.47 in petitioners’ Federal income tax for the taxable year ended December 31, 1979. After concessions, the sole issue for decision is what was the fair market value, on October 9, 1979, of an open-space easement which petitioners donated to the Virginia Outdoors Foundation. For reasons of convenience, we have combined our findings of fact and opinion.
Some of the facts have been stipulated and are so found. This reference incorporates the stipulation of facts and attached exhibits.
Petitioners are husband and wife and…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Olson v. United StatesSupreme Court of the United States · 1934
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Parker v. CommissionerUnited States Tax Court · 1986
- Messing v. CommissionerUnited States Tax Court · 1967
10 more not listed; retrieve them via the Exa API.
3Cited by91 opinions
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- Whitehouse Hotel L.P. v. Comm'rUnited States Tax Court · 2008
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