Transamerica Corporation v. The United States

NIES, Circuit Judge.

Transamerica Corporation (taxpayer) appeals from the judgment of the United States Claims Court, 15 Cl.Ct. 420 (1988), (Harkins, Sr. J.) affirming the disallowance of taxpayer’s claim for a charitable contribution deduction under 26 U.S.C. § 170(a)(1) (1982) in the amount of $10,045,-480 for the taxable year ending December, 1969, by reason of the transfer of certain rights in motion picture film stock to the Library of Congress. We affirm.

I

In a lengthy analysis, the Claims Court detailed the facts with respect to the unusual nature of motion picture film stock which is…