Taxpayers’ valuation of property off by $11 million

The taxpayers valued the property sold to a charitable organization at $15.8 million and claimed a total charitable contribution deduction on the basis of their appraisal of the property compared to the bargain-sale price the charity paid for it. In reviewing the transaction, the Internal Revenue Service concluded that the property was worth only $4.05 million and reduced the claimed charitable contribution deduction taken over several years on the taxpayers’ returns by more than $11 million.  The Tax Court has affirmed the IRS valuation and its imposition of the 40% gross valuati