Martin H. Droz - Page 6

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          Mark IV helmet at issue was worth approximately $400 to $500, and           
          he offered to purchase it for a price within that range.                    
               About one to two years after his initial telephone conversa-           
          tion with Dr. Jamieson, petitioner telephoned Dr. Jamieson and              
          offered to sell him a Mercury helmet.  Dr. Jamieson recognized              
          the caller's voice as that of petitioner, informed petitioner               
          that the helmet that he was offering for sale was a Mark IV                 
          helmet and not a Mercury helmet, and advised petitioner that the            
          value of the helmet petitioner owned was approximately $400 to              
          $500.                                                                       
               About two months after his initial telephone conversation              
          with Mr. Gilliam, petitioner telephoned Mr. Gilliam.  Upon                  
          discovering that he had had a prior telephone conversation with             
          Mr. Gilliam, petitioner terminated that second telephone conver-            
          sation.                                                                     
               During 1991, petitioner donated the Mark IV helmet that he             
          had purchased in June 1977 to the Liberal Air Museum (museum) in            
          Liberal, Kansas.  By letter dated June 23, 1992, Stephen G.                 
          Brown, Executive Director of the museum, confirmed that that                
          helmet was in the possession of the museum.                                 
               In his 1991 Federal income tax return (1991 return), peti-             
          tioner, who had no expertise in personal property valuation,                
          valued the Mark IV helmet that he had donated to the museum at              
          $76,700 and claimed a charitable contribution deduction in the              





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