In Rolfs, both the Tax Court and the Seventh Circuit agreed that all of the statutory requirements were in place to support a charitable contribution deduction.
Tony Nitti notes that there was a dissent in the Patel case, but that the dissenting judge indicated that the logic of the Rolfs case would have had to have been addressed regardless.
In Rolfs we held the taxpayers had not made a charitable contribution because they received a substantial benefit in the form of demolition services, the value of which exceeded the value of the interest in the house donated.