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community organizations. The Players operate the Peninsula
Center Stage with financial support from the City of Redwood
City. The Players receive approximately $30,000 per year from
the City of Redwood City.
In 1990 and 1991, the Players received from the City of
Redwood City a grant to upgrade the water delivery system for the
sprinkler system located over the stage area of the theater.
Since 1986, the Players have spent less than $100,000 in repairs
and renovations on the Redwood City Fox, primarily for the
sprinkler system upgrade and the addition of new roofing over the
theater.
Despite the lack of on-site parking, there was "ample"
parking around the property, and parking for events at the
Redwood City Fox has not been considered a problem.
VI. Petitioners' Valuation and Charitable Contribution
Deductions
A. Ingram/Ewing Appraisal
In order to ascertain the amount of their charitable
contribution deduction for their donation of the Redwood City Fox
in taxable year 1986, petitioners retained David Ingram, Inc., a
real estate appraisal firm located in Foster City, California, to
prepare an appraisal of the Redwood City Fox. The appraisal of
the property was performed by David Ingram, Jr. (Ingram)20 and
20 David Ingram, Jr. died in November 1993. Consequently,
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