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Mark IV helmet at issue to the museum. Nor do they dispute that
the museum qualifies as a charitable organization. The only
dispute is the fair market value of that helmet.
Petitioner contends that, as of the date he donated the Mark
IV helmet at issue to the museum, its fair market value was
$76,700. Respondent determined in the notice of deficiency she
issued to petitioner for 1991 that petitioner did not substan-
tiate the charitable contribution deduction he reported in his
1991 return that was based on that claimed value. On brief,
respondent contends that, based on the record in this case, the
fair market value of the Mark IV helmet at issue was between $300
and $500 as of the time petitioner donated it to the museum.
The fair market value of property that is the subject of a
charitable contribution is an issue of fact to be determined from
an examination of the entire record. Zmuda v. Commissioner, 79
T.C. 714, 726 (1982), affd. 731 F.2d 1417 (9th Cir. 1984). In
arriving at that determination, the Court will weigh its judgment
heavily against the taxpayer who is responsible for any deficien-
cies in the proof required to substantiate the value claimed.
Id.
The only testimonial evidence relating to petitioner's
claimed valuation of the Mark IV helmet at issue is petitioner's
testimony. As stated above, we are unwilling to rely on that
testimony. Even assuming arguendo that we were willing to rely
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