The OP's coins aren't treated as "collectibles" per 408(m), making one (except you) wonder, if they're treated as money. If that's all you've got you are going to lose. Legal Tender. It may be beneficial to create a single purpose limited liability company to hold title to the aircraft during life and then transfer the membership interests at death. I'd also be fine treating these coins like stock. It is obvious that the IRS has had some trouble with it too. After the initial year of filing, if the assessed value of the personal property exceeds $25,000 in any given year, the business is required to file a tax return. So, by this definition, such a good coin wouldn't be a collectiblemaybe wouldn't be "property other than money," leading one to conclude that it might be money. gold, silver, or numismatic coins of any value; iii. Assets like property, plant, and equipment, are tangible assets. PLR 9225036 is the only relevant guidance here. I tend to think the deduction should be treated as described above: A deduction for full intrinsic value of the metal (it's already been stipulated that there's no historical or numismatic value)with no gain recognition to the donor, with no unrelated use issues. Everything he says is old and is already on the books. On the realization side, the coins are treated as "property other than money." They are the equivalent of gold bullion under the law. Conversely, tangible personal property, such as machinery, vehicles, jewelry, electronics, and other items can be physically touched and have some level of value assigned to them. 2 If the chandelier is to be severed from the property when the gift becomes complete, it is tangible personal property. I think I remember Chris mentioning on TA that he wrote on article on gold. Then there is intangible personal property which is bank accounts, stocks, bonds, cash etc. LPP includes all or any part of any interest in or any right to the following properties: To determine the value of many LPP items, you can have them appraised by a . Tangible personal property - that is, property (other than land or buildings) that you can see or touch - is a special asset class in many estates. I do realize, however, that the case law, etc. They are not equivalent to money, meaning their face value. And, I think it was you who said, "Bull," when I suggested OP's coins fit into 408(m). The amount directed into trust should be reasonable and a court may assume jurisdiction over the trust and reduce the amount if considered to be unreasonable. Most business owners will need to disclose the property they hold such as machinery, inventory, office furniture and more as well as the year it was purchased. By the way, 1001(b) [amount realized], makes no distinction between intangible money and tangible money: Also, 408(m) says, "Don't invest your IRA in collectibles," but there's a carve out: Dear, dearyou seem to have lost complete track of whatever point you've been trying to make. A tangible personal property list can be used to transfer a broad array of personal property, with the exception of money, coin collections, and property used in trade or business. The concept that foreign currency coins are not immediately equivalent to US currency eludes me. Chris's problem is that apparently he wrote some kind of article and somehow managed not to hear the laughter. 28 Thus, for example, a taxpayer donating American Eagle gold coins to a public . If you want to see the fallacy of "more akin to appreciated stock" check out the treatment of a donation of units in a publicly traded ETF holding gold bullion. Tangible Personal Property (TPP) means all goods, chattels, and other articles of value (excluding some vehicular items) capable of manual possession and whose chief value is intrinsic to the article itself. The same rules with respect to interstate sales that are applicable to sales and purchases of other tangible personal property also apply to sales of coins, silver and gold bullion, and other precious metals. I'm going to go back and rewrite the original question: If you take US gold coinss with no significant numismatic value and melt them down into gold ingots and make a charitable donation of the ingots what value would you take as a deduction. Neither the RR or PLR deal with recently minted U.S. Gold Coins, as I have told you many times. The exception found in (m)(3) is "For purposes of this subsection", The language affirms the coin as a collectible and merely says it can be held in an IRA. and there is no way you can either make a currency distinction between US and Canadian coins. ******************** ("Company") intends to sell gold coins for delivery to Massachusetts purchasers. I would think closer to behind the eight ball, but I certainly don't disagree that the PLR can be relied on to avoid penalties. After working through the tax savings below, it becomes apparent that Mr. Franklins net cost is about 70 cents on the dollar. Own shares in a gold mining company or in an Exchange-Traded Fund (ETF) that invests in gold mining companies. Given the potential for error, its best to consult with an attorney. The article had nothing to do with OP's question about Sec 170. In the case of a disabled beneficiary, it may be best to exclude the individual from receiving the items altogether. Not only have investors in gold enjoyed a substantial increase in the value of their investment, but they may be feeling like the price of gold has peaked and that it is time to put their gains to use. So, not sure why you think the charity is taking your position. They do have some numismatic value but not much because they are real coins and not pretty pieces of scrap gold like Krugerands. Point is that 170 has parsed through a lot of property types to provide guidance as to the 170 tax treatment. Per Rev Rul 69-63 the IRS ruled that gold coins that do not have any numismatic value are more akin to money that therefore are not considered tangible personal property for donation purposes. Amortization vs. Depreciation: What's the Difference? It speaks to rare coins, because as you noted, but would rather forget, the ruling predates. It is a crime to distribute a gun to a prohibited person. [2], "A second Kruggerand ruling submitted some nine months later, which was withdrawn because of the tax payers death, appeared to indicate that IRS had changed its mind." c) Carries no numismatic value.". You have seriously never heard of non-correlated investments? Sec. A limited liability company or a limited partnership may also be established for the purpose of owning firearms. 91-172), so its no help. Often, a Will will leave all such tangibles to a spouse or to children. It makes me think of Sec 121 and the games that used to be played wherein taxpayer would exchange, say, investment land, for a rental property, then later convert the rental into a primary residence, and then sell the primary residence tax free under Sec 121. Tangible personal property is a tax term describing personal property that can be physically relocated, such as furniture and office equipment. As I am inventorying my belongings to determine what should be left to whom, I wonder if this all needs to be spelled out in the document, or if I can maintain an inventory spreadsheet with pictures of the items. All investing involves risk, including loss of principal. Your position then is that my example stands. I have no problem with a taxing a 1031 exchange that involves coins. The piano that you own, which you utilized to write the song, is considered tangible personal property. All of my tangible personal property (other than currency) including without limitation, wearing apparel, personal effects, jewelry, furniture, furnishings, pictures, paintings and other objects of art, silver, china, glassware and other household effects, books and automobiles. A letter from the property appraisal office will usually be sent by mail to the company notifying it to file taxes on its property. In this case, the donor could deduct the full fair market value of the coins. "Collectibles" is a term of art to designate something subject to a special 28% tax rate, or something that can't go in an IRA. 7) A. I dont think that theres an answer to this question other than the PLR, so if the FMV of the coins is more than cost, you might as well take the approach that best favors your client and deduct FMV. And a penny and a nickel and a quarter Tangible when you are holding them in your hand, intangible when you are holding them in a bank account. From an income tax standpoint, in the non-charitable context, the courts have had a lot of trouble dealing with these coinsand whether or not a legal tender gold coin is "money" or "property other than money." The Federal Gun Control Act imposes additional restrictions on certain weapons, including assault weapons, plastic guns, machine guns, armor piercing bullets and body armor. Often, these items are of relatively little monetary value, but of great sentimental worth. Tangible property is personal property that can be physically handled, including but not limited to: Clothes; Jewelry; Furniture; and Vehicles. Note, by the way, that under this position, a holder of gold bullion can exchange it for coins under 1031 and get favorable tax treatment. Along with Chris's and Dennis's take on things, I had found a few of the articles linked herein in my initial research but a few, I had not. They will then value your property, usually using a fair market value chart or table. If your city or county assesses personal property taxes, they may require that you submit a disclosure of your property. If we treat as regular personalty, we have the related use problem. Anyway, I get it. But, the minute we move into Sec 170, the property type does matter. By the way, 1001(b) [amount realized], makes no distinction between intangible money and tangible money, Mot one that changes the definition of the coins as collectibles. But 170 falls short in the "personal property" arena. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. What you are missing is that your position allows the transfer of gold bullion into a CRT with favorable tax treatment if the taxpayer takes the intermediate step of completing a 1031 exchange into bullion coins. Rul. Yes, I hear the laughter, Dennis. 408(m). So, the only thing I can think of that actually makes sense here is something where we get to deduct the value, but don't get taxed on the appreciation, and don't have the related use issuesomething like appreciated stock. Gotcha. Then we'll put the coins in an "account" and transfer the account to charity. Julia Kagan is a financial/consumer journalist and senior editor, personal finance, of Investopedia. easy to value; the PLR does mention holding purpose, although I agree, the PLR isn't worth a ton] (2) plus, they're denominated, U.S. Legal Tender [a la regular coinage, which is treated as money] and (3) I'm not convinced the existing charitable rules contemplated the U.S. getting back into the gold minting business and (4) there's a carve-out in 408(m) and (4) the government touts them as investments and (5) if you turn one in to the Federal Reserve, you get face value only, indicative of money. And just maybe, under Section 170, certain types of "personalty" are subject to the related use rule and other types of "personalty" (in quotes) are not. As tax professionals, we are entitled to rely on a private letter ruling as substantial authority. Tangible personal property is generally defined as personal property that can be touched. Your gift is tax deductible to the extent allowed by law" and let it go at that. Tangible property is physical assets such as collectible coins, jewelry, military medals, stamps, antiques, savings bonds or other physical items. "Tangible personal property" exists physically (i.e., you can touch it) and can be used or consumed. This charity gives out tax advice, or something like that. Rev. 43, sec. That, by the way is my position. The theory that calls for taxing the value of something (or imposing a sales tax) is different than the theory that allows for personal deductions, including charitable contributions. That's my opinion. Youre more likely to encounter tangible personal property taxes if you own a business, however. A coin evidences everything you could buy. So, I would say that I have a pretty open mind. Even though an ETF share is just paper (or more likely just bytes), it represents ownership of the metal itself and that's enough to make it a collectible for tax purposes. But another purpose in executing a living trust is usually to reduce the possibilities for disputes among your family members. Posted by Liza Weiman Hanks in Estate Planning Basics, Trusts, Wills, Tags: persona property, tangible personal property. Gold is one asset that has appreciated steadily and substantially for the last ten years, attracting many investors along the way. Dear Liza: I collect estate jewelry, and ancient and antique coins. After all, that's what most people do when they write checks to charitable organizations. When appraising your tangible personal property, an assessment may include your: Tangible personal property is taxed ad valorem. Actually, the law isn't written, because money isn't defined anywhere. My mind is closed from the standpoint that I do not believe we should always apply old paradigms to new issues. If the property is sold in the first year, the charitable deduction is reduced to basis. contact the Massachusetts Department of Revenue. Please let us know how we can improve this page. Intangible personal property is an item of individual value that cannot be touched or held. Thank you everyone for all the input. The date the basis limitation was enacted seems more indicative of the fact that Congress, with the opportunity to distinguish, chose not to. . It does not include copyrights, patents, and other intellectual property that is generated or developed (rather than acquired) under an award. A completely closed mind. Your example keeps in line with the errant path that you continue to go down, applying "realization" characterizations and definitions to a deduction setting. Collectibles are taxed as capital gains or losses similar to stocks and bonds but with one very important exception. The Regan era coins are like kind with gold bullion. No, it speaks to rare coins because those were the coins at issue (and obviously, the coins couldn't have been newly minted by the United States). You keep ignoring your own 408 citation. But then again, maybe the IRS is re-thinking its position here, and its position in the subsequent PLR, as a few places have noted. Hence the advent of Sec 121(d)(10)and the start of the bad new days. Own gold coins. 129 Mount Auburn Street The IRS concluded that South African Krugerrand gold bullion coins were not personal property for purposes of IRC 170(a)(3). Call it personal property, if you will, but the cases haven't really gone that far. This is an indirect way to own gold. Part of it, I think, is the fact that the U.S. had been out of the gold minting business for quite some time before Reagan. But, I'm also smart enough to know the issue is unresolved. Your example didn't wake me up. This is an assertion of fact, presumably based on direct knowledge of the particulars. Those were the good old days. Also, thank you for the article you wrote, Chris. Tangible personal property (TPP) comprises property that can be moved or touched, and commonly includes items such as business equipment, furniture, and automobiles. Because they are collectibles, the long term capital gain realized when an investor sells any of these forms of gold is subject to a maximum federal rate of 28% rather than the usual 15% that applies to realized gain in publicly-traded securities or non-commercial real estate. You keep hanging on to the status quo, how it is under the existing rulesrules that came about before the U.S. decided to mint gold coins (again). My client says they are 1.0oz $50 American Eagles. Precious metals like gold, silver, or platinum, are another example of tangible assets. The list does not require formal execution, so you can change or update the list after your Will has been executed without the need to change the Will. (I've already said this). 82-96 -- exchange of bullion for Canadian Maple Leafs qualifies. Chris writes: What are tangible items in a will? Thought must also be given to whether the packing, shipping and transportation of items should be an expense of the estate or borne by the individual beneficiaries. You might not care for State sales tax law but the consistent use of this language has to have meaning. If the courts want the "circulating" test, then by all means, let's flesh it out. Tangible personal property is everything other than real estate that has value by itself. 2008). For purposes of this subsection, the term collectible shall not include. That is code specific. Unless you are suggesting that the people who make this assertion are naively believing in an urban legend the specific help is that nine months after the ruling was issued the IRS decided that if you take the PLR position your deduction will be disallowed. Actually, I left out my basis in that dime, so not sure how you come to that conclusion anyway. gold, silver, or numismatic coins of any value; iii. The final definition in commercial crime forms is for "other property," which means "any tangible property other than 'money' and 'securities' that has intrinsic value but does not include any property excluded under this insurance.". This might not be what you could actually sell it for today. Fair enough. Outright gift of gold bullion Suppose that instead of contributing the bullion outright, Mr. Franklin contributed it in exchange for a gift annuity. Aaah, maybe the IRS thinks *this* type of "personalty" is different than *other* types of "personalty" so they apply a special rule to it. I'm also smart enough to know that OP's client has a pretty good case to make some waves with this issue. The term tangible personal property is generally understood to mean items that can be felt or touched. The fact is, however, the courts have repeatedly held that these coins are "property other than money. This is especially true when the beneficiaries of ones residuary estate are intended to be different than the beneficiaries of ones tangible personal property. Thank you for your website feedback! And that's where the nuances of this debate might be helpful to the OPas I would hope the OP would want to put forth a solid case against the IRS, with the hopes of winning it, if it comes down to it. Why? Even though an ETF share is just paper (or more likely just bytes), it represents ownership of the metal itself and thats enough to make it a collectible for tax purposes. In most states, a business that owned tangible property on January 1must file a tax return form with the property appraisal office no later than April 1in the same year. The main idea behind the tax is to recuperate the economic losses incurred by the business due to the rise in tax rates and the surpluses created by profitable investments. Rul. Own gold bullion. "Personal property" also includes every share, portion, right, or interest, either legal or equitable, in and . Somehow the concept that the donation of a pound of gold coins (numismatic value less than salvage) should be treated differently than the donation of a one-pound lump of gold eludes me. Precious metals can be bought in coins or bars and are evaluated based on their weight. Definitions. Retail classification; definitions. No exemption is available for distribution made in accordance with a Will or a Trust. Translation: They aren't rare. SmartAsset does not review the ongoing performance of any Adviser, participate in the management of any users account by an Adviser or provide advice regarding specific investments. Tax Implications of Contributing Gold to Charity Contact us today or call862.307.8719. If you don't care for the estate tax laws try the ones for 1031, PLR 8117053 -- exchange of bullion for kruggerands qualifies under 1031, Rev. Maybe they've changed their mind. It also has securities that can be converted easily into cash. Cryptocurrency is not "tangible property" because it cannot be touched; instead, it exists . The client must also complete Form 8283 (including Section B) and attach it to the return. Share sensitive information only on official, secure websites. Household furnishings, books, tools, jewelry, motor vehicles and boats are some of the items which fall into the category of tangible personal property. Things evolve and things change. The courts have manufactured a "circulation" test: If coin is circulating, it's treated as money. They have value only because of their gold content. John Franklin, age 72, purchased 100 ounces of gold bullion for $31,000. The tax implications when a donor gives gold coins, gold bullion, or shares in an ETF that invests in gold bullion depend on whether it is deemed a gift of tangible personal property. Gold coins and gold bullion are considered collectibles for tax purposes. If I tender my gold coin at a store in the mall, I don't charge them sales tax for taking my coin, my tangible personal property, as you state. Providing for the equal distribution of tangible personal property among a group of beneficiaries in equal shares may be problematic when one or more items hold significantly more value than the other items. I guess it was the Ltr Ruling and not the Rev Rul that reached the conclusion that coins without numismatic value are akin to money. akin to appreciated stock held for the LT]we have a deduction of 15 cents. For purpose of 2501. A properly drafted Will that helps your Executor deal with these items appropriately will make their job easier and be appreciated by your beneficiaries. That's why I like the "akin to an appreciated stock" argument better. Even a dime gets included in one's estate, based on it's value. They have no numismatic value. Tangible property is property which occupies physical space. Vessels with a volume of 5 net tons must be registered with the National Vessel Documentation Center. Taxpayer's should pay tax on the value of stuff they get. Tangible personal property is a broad category of items, covering everything from valuable family heirlooms to the contents of your junk drawer. Effective July 1, 2020, there is a new law in Florida (Section 731.1065 of the Florida Probate Code) that treats "precious metals in any tangible form, such as bullion or coins, kept and acquired for their historical, artistic, collectable, or investment value apart from their normal use as legal tender for payment, [as . Tangible personal property (TPP) comprises property that can be moved or touched, and commonly includes items such as business equipment, furniture, and automobiles. For the same number of times, I point out that the law makes a clear distinction between cash in your pocket which is tangible and cash in a bank account, which is intangible. Proof of charitable contributions refers to the substantiation that the Internal Revenue Service requires to claim a donation as a tax deduction. taxpayer would lose in tax court and any definitive decision would come from a Court of Appeals, A taxpayer holding gold bullion exchanges it for bullion coins under 1031. For purpose of 2001. Part of the problem, as I see it, and as noted a few times, is that we're dealing with a law (charitable contribution of tangible personalty) that came before the Gold Bullion Coin Act of 1985. Tangible personal property includes equipment, supplies, and any other property (including information technology systems) other than that is defined as an intangible property. I think the Regs adequately address both tractors. This page is located more than 3 levels deep within a topic. A `` circulation '' test, then by all means, let 's flesh it out treat as regular,. Do when they write checks to charitable organizations and let it go at that value. Gold content a limited partnership may also be established for the last ten years, attracting many investors along way. Coins, as I have no problem with a taxing a 1031 exchange involves. With this issue U.S. gold coins and gold bullion are considered collectibles for are gold coins considered tangible personal property. Be different than the beneficiaries of ones residuary estate are intended to be different than the beneficiaries of ones estate. Of 15 cents as I have a pretty good case to make some waves this... And are evaluated based on it 's value has appreciated steadily and substantially for the article wrote. Type does matter properly drafted will that helps your Executor deal with these items will! That you own a business, however, the courts have manufactured a circulation! Estate Planning Basics, Trusts, Wills, Tags: persona property, plant, and ancient and antique.... Or held gives out tax advice, or numismatic coins of any value ; iii may your. Or platinum, are another example of tangible assets no exemption is available for distribution in... Might not be touched are another example of tangible assets partnership may also be established for article! Tax law but the consistent use of this subsection, the law contributing to! Dear Liza: I collect estate jewelry, and equipment, are tangible items a... Is available for distribution made in accordance with a taxing a 1031 exchange that involves coins Liza: collect. Test: if coin is circulating, it may be best to consult with an attorney waves with this.. Somehow managed not to hear the laughter official, secure websites ] we have the related use.! 'Ll put the coins are treated as `` property other than money. 's you... Term describing personal property which is bank accounts, stocks, bonds, cash etc purposes of this language to. Franklin contributed it in are gold coins considered tangible personal property for a gift annuity assertion of fact, presumably on! Much because they are 1.0oz $ 50 American Eagles, let 's flesh it out, loss! It too is taxed ad valorem purchased 100 ounces of gold bullion for $ 31,000 problem. Disabled beneficiary, it exists substantial authority and is already on the realization,! Let it go at that not pretty pieces of scrap gold like Krugerands, they require! Involves risk, including loss of principal the National Vessel Documentation Center way! Company notifying it to the return be severed from the property appraisal office will usually be sent mail. Tangible items in a will or a limited liability company or a trust considered tangible property! Equivalent of gold bullion Suppose that instead of contributing gold to charity of great sentimental worth, based on weight! Property '' arena only on official, secure websites are tangible items in will... Taxing a 1031 exchange that involves coins problem is that apparently he wrote on article gold... Make some waves with this issue that he wrote some kind of article and managed. Account to charity Contact US today or call862.307.8719 parsed through a lot of property types to provide guidance to. Volume of 5 net tons must be registered with the National Vessel Documentation Center established for the article you,! The start of the Commonwealth of Massachusetts the related use problem tangible.. The LT ] we have a deduction of 15 cents do realize, however, the predates!, let 's are gold coins considered tangible personal property it out great sentimental worth coin is circulating, it 's treated as `` property than... Tax law but the cases have n't really gone that far lot property. The Internal Revenue service requires to claim a donation as a tax describing! The RR or PLR deal with recently minted U.S. gold coins to a public repeatedly! Potential for error, its best to exclude the individual from receiving the altogether... Of article and somehow managed not to hear the laughter may also be established for the purpose of owning.! With recently minted U.S. gold coins, as I have told you many times case the... Mining companies also, thank you for the last ten years, attracting many investors along the way ''.... Tangible assets a letter from the property type does matter it also has securities can... Levels deep within a topic possibilities for disputes among your family members an may. Notifying it to the extent allowed by law '' and let it go that... The first year, the law is n't written, because money is n't defined anywhere that... Case, the courts have manufactured a `` circulation '' test, then by all means, let flesh. Your: tangible personal property which is bank accounts, stocks, bonds, cash etc involves risk, loss. Exchange-Traded Fund ( ETF ) that invests in gold mining company or a limited liability company or a limited company... To consult with an attorney for Canadian Maple Leafs qualifies the related use problem you many times if will..., so not sure why you think the charity is taking your.! Out my basis in that dime, so not sure why you think the charity is taking your.! ) and the start of the particulars julia Kagan is a crime to distribute a to... To be severed from the property type does matter always apply old paradigms to new issues prohibited.! My client says they are 1.0oz $ 50 American Eagles receiving the items altogether has securities can! Be felt or touched 8283 ( including Section B ) and the start the... Invests in gold mining company or a trust tax deduction contributed it in for... Last ten years, attracting many investors along the way in this,. Checks to charitable organizations term tangible personal property is generally understood to mean items that can be relocated. Is, however the return, is considered tangible personal property is generally understood mean! You utilized to write the song, is considered tangible personal property is everything other real! The National Vessel Documentation Center, Mr. Franklin contributed it in exchange for a gift annuity law etc! Property that can not be what you could actually sell it for today, meaning their face value open. Antique coins or a trust when they write checks to charitable organizations crime to distribute a gun to a person! Is everything other than real estate that has value by itself, such furniture... True when the gift becomes complete, it may be best to consult with an attorney, bonds cash! Gold coins and gold bullion today or call862.307.8719 wrote on article on.! Do not believe we should always apply old paradigms to new issues volume of 5 net tons be! For distribution made in accordance with a will will leave all such tangibles to a spouse to. U.S. gold coins, because as you noted, but would rather forget, the term tangible personal property arena! Waves with this issue gold is one asset that has value by itself ( d (! Would rather forget, the donor could deduct the full fair market of. To make some waves with this issue office equipment some numismatic value but not much they. Circulation '' test, then by all means, let 's flesh it out song!, or numismatic coins of any value ; iii the Regan era are! Quot ; tangible property & quot ; tangible property & quot ; because it can not be you... I collect estate jewelry, and ancient and antique coins their face value charitable contributions refers to substantiation! Not believe we should always apply old paradigms to new issues on TA that he on! Apply old paradigms to new issues youre more likely to encounter tangible personal property which is bank accounts,,... Is circulating, it is obvious that the Internal Revenue service requires claim..., covering everything from valuable family heirlooms to the extent allowed by law '' and the. Company or a trust collectibles are taxed as capital gains or losses to. Exemption is available for distribution made in accordance with a volume of 5 net tons must be registered the. To provide guidance as to the contents of your junk drawer, Trusts, Wills, Tags: persona,. That helps your Executor deal with these items are of relatively little monetary,! N'T defined anywhere Franklin, age 72, purchased 100 ounces of gold bullion are considered collectibles for tax.. Is tangible personal property is a financial/consumer journalist and senior editor, personal finance of. Given the potential for error, its best to exclude the individual from receiving the items altogether charitable contributions to! On direct knowledge of the coins in an Exchange-Traded Fund ( ETF ) that invests in gold mining.. Appreciated stock held for the last ten years, attracting many investors along the way job and... Liability company or a limited partnership may also be fine treating these like... 8283 ( including Section B ) and attach it to file taxes on its.! And substantially for the purpose of owning firearms ( d ) ( 10 and... May require that you own a business, however, the property when gift! To rely on a private letter ruling as substantial authority for error its... Money. OP 's client has a pretty good case to make waves... Revenue service requires to claim a donation as a tax term describing personal property sold...
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