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the value of the retail/office spaces to be $1,448,419, broken
down as follows:
Price Per Total
Square Foot Square Feet Total
East Side Retail/Office $103.00 2,625 $ 270,375
Space (without mezzanine)
West Side Retail/Office 103.00 2,105 216,815
Space (without mezzanine)
East Side Mezzanine 65.92 2,625 173,040
West Side Mezzanine 65.92 2,226 146,738
Office Space (without 103.00 6,090 627,270
Fourth Floor)
Fourth Floor 79.31 876 69,476
16,547 $1,503,713
Less Estimated Cost of Restoration (55,295)
Total Market Value Estimate $1,448,419
5. Ingram/Ewing--Value Reconciliation
In summary, Ingram/Ewing estimated the following values for
the Redwood City Fox under their application of the replacement
cost approach and the comparable sales approach:
Cost Market Final Estimate
Theater $3,776,390 $3,850,115 $3,850,000
Retail/Office 1,472,366 1,448,419 1,448,000
Total $5,299,000
Ingram/Ewing rounded this figure to arrive at $5,300,000 as their
estimate of the fair market value of the Redwood City Fox as of
December 31, 1986.
B. Petitioners’ Charitable Contribution Deduction
Petitioners used the services of an accountant to prepare
their 1986 Federal income tax return. Based on the Ingram/Ewing
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