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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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