Prepare a file memorandum that will outline and explain the process by which one of the firm's wealthier clients - let's call her "Ms. Billions" - can determine and defensibly deduct the value of an old master painting that she plans to donate to the Metropolitan Museum of Art. In connection with updating her insurance coverage on the painting ten years ago, she had obtained an appraisal stating that the painting was then worth an estimated $3 million. She has not had a more recent appraisal done but assumes that the value would be much higher today.  

Your memo should objectively explain the relevant tax issues, including common pitfalls to be on guard against. As to the contribution planned by Ms. Billions, that most certainly would include, but perhaps not be limited to, the valuation issue. (You may assume that there is no provenance issue, so no need to discuss). 

Your memo, addressed to the "Senior Partner," should include - 

• discussion of the basics of claiming a charitable contribution deduction for this kind of contribution; and
• discussion of IRS resources and/or processes relevant to this kind of con-tribution deduction, especially the valuation issue; and
• brief reference(s) to at least two tax cases (court decisions), Tax Court or otherwise, dealing with charitable contributions of museum-quality fine art and reflecting the attitude and approach of judges in handing litigated tax issues involving the contribution of high-dollar fine art; and any other matter that you deem relevant enough to warrant mentioning.