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sity as part of the final exchange transaction. At the time Mr.
Signom transferred the Irving property to the University, it
declared the value of that property for Ohio transfer tax pur-
poses to be $165,000. Petitioners argue that the value of the
Irving property for Ohio transfer tax purposes is not the fair
market value of that property and that the value of that property
for Ohio transfer tax purposes is irrelevant to a resolution of
the issue before us under section 170.
On the record before us, we are unable to determine whether
petitioners are correct that the value of the Irving property for
Ohio transfer tax purposes was not the fair market value of that
property when Mr. Signom transferred it to the University.
However, we need not resolve that question in order to determine
whether petitioners are entitled to a charitable contribution
deduction under section 170 as a result of the cancellation of
MHR Properties’ St. Clair property interests. What is signifi-
cant in our resolving that issue is that pursuant to Ohio law the
University, as the grantee of the Irving property, declared the
value of that property for Ohio transfer tax purposes to be
$165,000, and Mr. Signom, as the grantor of that property,
acquiesced in that valuation when, as required by Ohio law, he
paid the Ohio transfer tax based on that declared value with
respect to his conveyance of the Irving property to the Univer-
sity as part of the final exchange transaction that occurred on
August 1, 1991.
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