- 24 - 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.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011