On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Campbell v. Commissioner (T.C. Memo. 2020-41). The primary issue before the court in Campbell v. Commissioner was whether petitioners are entitled to a charitable contribution deduction with respect to donation, which hinges on the issues of whether the taxpayer submitted appropriate substantiation for the contribution and/or reasonably relied on the advice of a CPA that the charitable deduction was appropriate. Background to Campbell v. Commissioner In 2006, petitioner-husband learned about a charitable program (through his CPA) that sold units of eyewear (approximately 3,500 pairs of glasses per unit) for $50,000, the purchaser of which unit could then (purportedly) donate the glasses (after a 1-year holding period) to a qualified IRC § 501(c)(3) organization and claim a charitable deduction at the appraised FMV of the eyewear at the time of the donation, which was advertised as…