The Tax Court has agreed with the Internal Revenue System and denied an appreciated appraised value charitable contribution deduction for a gift of art that a donor claimed he purchased more than a year before giving it to charity. The Court has also affirmed a 20% negligence penalty. The donor entered into an agreement with Abbey Art Consultants in New York City in 1996, under which he agreed to spend $72,000 for art, provided that the total purchase price would not exceed 24% of the cumulative appraised fair market value of the works purchased. He paid 5% of the purchase price, with the balance to be paid when he accepted physical possession of the art or it was delivered to and accepted...