Jerrold E. and Helen C. Arbini - Page 5

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          period of January 1915 (only 7 months for 1915) through June 1951           
          (single issue volumes).                                                     
          In total, 33,710 newspapers were donated to the SFACA with a                
          combined weight of approximately 2,170 pounds.  The newspapers              
          were in firmly bound volumes and were in above-average condition.           
               In 1998, Ohio State University purchased the entire                    
          newspaper collection of the SFACA for $100,000.  The Los Angeles            
          and Chicago newspapers donated by petitioner and Mr. Fagliano               
          constituted a small portion of the collection purchased by Ohio             
          State University.                                                           
               Petitioners’ Federal income tax return for 1991 included a             
          Form 8283, Noncash Charitable Contributions, claiming a                     
          charitable contribution of $589,925 attributable to one-half of             
          the value of the Los Angeles and Chicago newspapers donated to              
          the SFACA.  Attached to petitioners’ return was an appraisal,               
          dated January 25, 1991, from Hal Verb (Mr. Verb).  In the                   
          appraisal, Mr. Verb stated that the estimated saleable value of             
          the newspapers, not including the magazine and Sunday comic                 
          sections, was $1,179,850.4  On the basis of the percentage                  
          limitations on charitable deductions, petitioners limited the               
          amount of their charitable deduction for the newspapers for 1991            
          to $144,448 and carried the excess contribution forward to 1992.            

               4Mr. Verb determined that the newspapers had an average                
          value of $35 per issue and multiplied this figure by 33,710, the            
          number of issues donated to the SFACA.                                      

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