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DOHERTY v. C.I.R.

No. 92-70596.

16 F.3d 338 (1994)

George O. DOHERTY; Emelia A. Doherty, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 8, 1994.

Attorney(s) appearing for the Case

Daniel C. Doherty, Manning & Murray, Arlington, Virginia, for the petitioners-appellants.

Scott C. Towers, United States Department of Justice, Washington, D.C., for the respondent-appellee.

Before: WRIGHT, CANBY, and T.G. NELSON, Circuit Judges.

CANBY, Circuit Judge:

OVERVIEW

George and Emelia Doherty appeal the Tax Court's determination of the fair market value of a painting they had donated to a museum. As a result of this determination, the Tax Court found the Dohertys liable for tax deficiencies for tax years 1982 and 1983. We affirm.

I.

In 1969, the Dohertys bought "Attacking Stagecoach," which may or may not have been painted by Charles M. Russell, for $10,000. They donated...

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