Johnson v. Commissioner
United States Tax Court
P's purchased a substantial number of Indian artifacts and etchings. After holding them for the required capital gain period, P's donated substantially all the artifacts and about two-fifths of the etchings to a qualified charitable organization. A pattern of abuse designed to achieve excessive valuations of the donated items was evident. The donated items were grossly overvalued.
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P's purchased a substantial number of Indian artifacts and etchings. After holding them for the required capital gain period, P's donated substantially all the artifacts and about two-fifths of the etchings to a qualified charitable organization. A pattern of abuse designed to achieve excessive valuations of the donated items was evident. The donated items were grossly overvalued. Held, respondent's valuation of the donated items reflects fair market value as of the dates of donation. Held, further, we find, sua sponte, an addition to interest under sec. 6621(d), I.R.C. 1954, to be…
1Opinion of the Court
Hamblen, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes:
Year Deficiency
1976. $8,195
1977. 17,217
1978. 152
The issues in this case are the fair market value of certain Indian artifacts1 and etchings donated to the Museum of Native American Cultures (monac)2 and the application of section 6621(d)3 as to interest on substantial underpayments attributable to tax motivated transactions.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly. The stipulation of facts and attached exhibits are incorporated herein by this reference.
Pe…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. CartwrightSupreme Court of the United States · 1973
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Messing v. CommissionerUnited States Tax Court · 1967
1 more not listed; retrieve them via the Exa API.
3Cited by82 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Parker v. CommissionerUnited States Tax Court · 1986
- Rose v. CommissionerUnited States Tax Court · 1987
- Solowiejczyk v. CommissionerUnited States Tax Court · 1985
- Patin v. CommissionerUnited States Tax Court · 1987
77 more not listed; retrieve them via the Exa API.