Weil v. Commissioner

In 1960, the Weils (plaintiff) donated a painting by Frederick Ede to the University of Maine. On their joint tax return for that year, they claimed a charitable-donation deduction for the painting, which they valued at $1,500. The Weils based their valuation on the opinion of Herbert Chase, an art appraiser. In November 1960, Chase visited the Weils’ home to examine the painting, and was told that his appraisal would be used for the purposes of claiming a charitable-contribution deduction on the Weils’ tax return. Chase appraised the painting’s fair market value as $1,500. The Internal Revenue Service (IRS) (defendant) disagreed about the painting’s value, determining that it was worth only $900 at the time of donation. The IRS issued a notice of deficiency, which the Weils challenged in tax court. At trial, the Weils called Chase as an expert witness. Chase was able to identify the donated artwork as an oil painting, and he recounted his visit to the Weils’ home to examine it. He could not, however, describe its subject matter, color, shape, or mode of creation. Chase also admitted to a lack of knowledge about Ede, acknowledging that he did not know the artist’s nationality or his typical subject matter. Moreover, Chase acknowledged that he did not know of any gallery that had sold Ede’s work and was unaware of any sales of other artworks by him. In determining the fair market value of the painting for charitable-contribution tax-deduction purposes, the court considered how much weight to assign to Chase’s appraisal.