Jerrold E. and Helen C. Arbini - Page 3

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          newspapers and obtained a 50-percent ownership interest in the              
          newspapers.  The Montana newspapers were stored in Mr. Fagliano’s           
          garage at his home in Bozeman, Montana.  Mr. Fagliano did not               
          take out separate insurance on the Montana newspapers, nor did he           
          increase his homeowner’s insurance beyond its then current                  
          $125,000 coverage.  At the time the Montana newspapers were                 
          purchased, neither petitioner nor Mr. Fagliano was a dealer in              
          rare or early newspapers.                                                   
               In 1990, a decision was made to donate the newspapers to the           
          San Francisco Academy of Comic Art (SFACA).  The SFACA was                  
          founded by Bill Blackbeard (Mr. Blackbeard) in 1969 as a research           
          center and library devoted to the American comic strip.  The                
          SFACA is a qualified section 170(c) organization.  Mr.                      
          Blackbeard, the director of the SFACA, was not interested in the            
          Montana newspapers and provided the name of Chris Berglas (Mr.              
          Berglas) to facilitate an exchange of newspapers in order to                
          provide the SFACA with newspapers it preferred.                             
               On July 5, 1990, Mr. Berglas, proprietor of The Authentic              
          Journal, a business involved in the retail of newspapers, agreed            
          to evenly exchange certain Los Angeles and Chicago newspapers for           
          the Montana newspapers.  The agreement required the Montana                 
          newspapers to be shipped to Mr. Berglas, who would then deliver             
          the Los Angeles and Chicago newspapers to the SFACA.  On August             
          9, 1990, the Montana newspapers were shipped from Bozeman,                  

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