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ANSELMO v. C.I.R.

No. 83-5569.

757 F.2d 1208 (1985)

Ronald P. ANSELMO and Kay W. Anselmo, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

April 16, 1985.

Attorney(s) appearing for the Case

Ralph A. Muoio, Caplin & Drysdale, Chartered, Stafford Smiley, Washington, D.C., for petitioners-appellants.

Joel Gerber, Acting Chief Counsel, IRS, Michael L. Paup, Chief, Appellate Section, Glenn L. Archer, Jr., Asst. Atty. Gen., Ann B. Durney, Elaine F. Ferris, U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before TJOFLAT and VANCE, Circuit Judges, and ATKINS, District Judge.

TJOFLAT, Circuit Judge:

This "charitable contribution" tax case presented the Tax Court with a classic battle of experts on the issue of the fair market value of the donated property, 461 low-quality Bolivian gems. The Commissioner's experts valued the gems as if they had been sold in bulk to a manufacturer of jewelry; the taxpayers' experts valued the gems as components of finished pieces of jewelry sold at retail. The...

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