Angell v. Commissioner
Angell v. Commissioner, 52 T.C.M. (CCH) 939 (T.C. 1986), aff'd, 861 F.2d 723 (7th Cir. 1988).
Petitioners Joseph S. and Patricia E. Angell claimed a charitable donation tax deduction on each of their tax returns for the period 1972-1980 for donations of artwork to two colleges. Respondent Commission of Internal Revenue determined deficiencies in the petitioners’ income tax for the period 1973-1980 claiming that petitioners’ claimed valuations were inflated. The Petitioners sought review, claiming . . . .