Taxpayer Wins Battle of Appraisers on Charitable Contribution.

The petitioners (a married couple) claimed a chartable deduction of $2.1 million resulting from the bargain sale of 63.39 acres of undeveloped land to a charitable foundation and their allocation and carryover of deductions from other years.  The issue in the case was the value of the contribution.  As is typical of cases like this, the result is fact-based with the outcome of which party had the better appraisal.  The court largely upheld the petitioner's claimed deduction, finding that the petitioners satisfied the contemporaneous written acknowledgment rule and had the better appraisal as to fair market value.  Davis v. Comr., T.C. Memo. 2015-88.

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