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As part of the donation to the Players, Jacobs gifted items
of personal property, described in the bill of sale executed on
December 29, 1986, between Jacobs and the Players. The items
donated were in good condition and all were functional. The fair
market value of the personal property on the date of donation was
$96,000.17
Contemporaneous with the gift of the property to the Players
and pursuant to the December 29, 1986, Agreement, Jacobs leased
from the Players approximately 12,268 square feet of the Redwood
17 Jacobs estimated the fair market value of the personal
property donated to the Players to be between $90,000 and
$100,000. Peter Morrison of Adamson Associates, Inc., a
professional cost estimating firm retained by petitioners in
1986, listed the following items of personal property donated and
their estimated values:
Bingo equipment $ 4,000
Fox film library 25,000
Fireplace 15,000
Baldwin theater organ 5,000
Kitchen and deli equipment 17,000
Stacking chairs 3,000
Double-decker London bus 21,000
Safe 1,000
Piano 1,000
Total $92,000
In their appraisal report, Ingram/Ewing stated that the correct
figure for the safe was $5,000, rather than the $1,000 listed in
the Adamson report. In light of the $87,444 allocated to the
personal property when Jacobs purchased the property in May 1981
and the fact that he subsequently purchased additional items
which he donated to the Players, we are satisfied that the
$96,000 figure is accurate. Respondent makes no argument against
this figure. Accordingly, we find that, on the valuation date,
the fair market value of the personal property donated by
petitioners to the Players was $96,000.
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