Jerrold E. and Helen C. Arbini - Page 7

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               The issue for decision is the fair market value of the                 
          donated Los Angeles and Chicago newspapers for purposes of                  
          determining the proper amount of petitioners’ charitable                    
          contribution deductions.  The parties agree that petitioners are            
          entitled to a charitable contribution deduction for one-half the            
          value of the newspapers; however, the parties disagree as to the            
          appropriate market to be used and the fair market value of the              
               Section 170 allows an individual to deduct charitable                  
          contributions, subject to certain percentage limitations, with a            
          carryover of any excess contributions.  See sec. 170(a), (b),               
          (d).  If a charitable contribution is made in property other than           
          money, the amount of the taxpayer’s contribution is the fair                
          market value of the property at the time of the contribution.               
          See sec. 1.170A-1(c), Income Tax Regs.  Section 1.170A-1(c)(2),             
          Income Tax Regs., defines fair market value as “the price at                
          which the property would change hands between a willing buyer and           
          a willing seller, neither being under any compulsion to buy or              
          sell and both having a reasonable knowledge of relevant facts.”             
          The fair market value of donated property as of a given date is a           
          question of fact to be determined from the entire record.  See              
          Goldstein v. Commissioner, 89 T.C. 535, 544 (1987); Skripak v.              

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