First an overview; then the Tax Court case. Some commentators have focused on a $33 million charitable deduction being completely disallowed because the donor failed to state the contributed property’s cost on Form 8283. Turns out that the Tax Court found the gift’s value was only $3.5 million, but still no allowable deduction.

Question: If the charitable deduction was fully disallowed, why are page after page of a 69-page opinion devoted to determining the gift property’s fair market value?