The court has no doubt that the taxpayers did donate some property to charitable organizations during 2011.

When the donor later decided to donate the property to charity, he simply enclosed a copy of this appraisal with the tax return on which a charitable contribution was claimed.

In 1934, his widow donated the property to the state.

From an early date, he planned on the group's donating the property it purchased to the federal government.

Rose, who by 1866 was tired of the hotel business, considered donating the property for educational purposes.