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1990, 1991, and 1992 because she determined that petitioners
Robson had failed to demonstrate the fair market value of the
donated items. For the same reason, respondent also disallowed
all charitable contribution deductions claimed by petitioners
Trnavsky for the years at issue. Respondent concedes that
section 212 provides a deduction for reasonable appraisal fees
paid to value a charitable contribution. However, respondent
amended her answers to the petitions and now contests as
unreasonable the amount of the appraisal fees deducted by
petitioners.
OPINION
Value of Charitable Contributions
Section 170(a) provides a deduction for charitable contribu-
tions made to qualified entities during the taxable year. The
regulations provide that, if property other than money is
donated, the amount of the contribution is the fair market value
of the property at the time of the contribution. Sec. 1.170A-
1(c)(1), Income Tax Regs. Section 1.170A-1(c)(2), Income Tax
Regs., defines "fair market value" as the price at which property
would change hands between a willing buyer and a willing seller,
neither being under a compulsion to buy or sell, and both having
reasonable knowledge of the relevant facts.
The determination of fair market value of donated property
is a factual inquiry. Estate of DeBie v. Commissioner, 56 T.C.
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