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a willing seller, neither being under any compulsion to buy or
sell and both having reasonable knowledge of relevant facts.
Sec. 1.170A-1(c)(2), Income Tax Regs. The standard is objective,
using a purely hypothetical willing buyer and seller. Propstra
v. United States, 680 F.2d 1248, 1251-1252 (9th Cir. 1982);
Estate of Newhouse v. Commissioner, 94 T.C. 193, 218 (1990). The
fair market value of property as of any given date is an issue of
fact to be resolved by considering and weighing all the relevant
evidence in the record. Symington v. Commissioner, 87 T.C. 892,
896 (1986); Skripak v. Commissioner, 84 T.C. 285, 320 (1985);
Zmuda v. Commissioner, 79 T.C. 714, 726 (1982), affd. 731 F.2d
1417 (9th Cir. 1984). While we must consider the entire record,
we have broad discretion to decide what facts are most important
in reaching our conclusion because "finding market value is,
after all, something for judgment, experience, and reason."
Colonial Fabrics, Inc. v. Commissioner, 202 F.2d 105, 107 (2d
Cir. 1953), affg. a Memorandum Opinion of this Court.
Petitioners have the burden of proving that the fair market value
of the donated property exceeds the value determined by
respondent in the notices of deficiency. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933); Estate of Gilford v.
Commissioner, 88 T.C. 38, 50-51 (1987); McGuire v. Commissioner,
44 T.C. 801, 806-807 (1965).
II. Fair Market Value of the Redwood City Fox
The experts' conclusions regarding the fair market value of
the Redwood City Fox as of December 31, 1986, are as follows:
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