Jerrold E. and Helen C. Arbini - Page 11

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          individual issues in the retail market, they must remove the                
          issues from their bindings, prepare them for sale, and locate               
          willing buyers for each date.  The purchase price of a newspaper            
          collection in the wholesale market depends on a variety of                  
          factors, including the condition, content, and date and title of            
          the newspapers.  The value attributable to an individual issue              
          generally diminishes when it is sold as part of a collection.               
               Both parties relied on the reports and testimony of expert             
          witnesses for purposes of determining the appropriate market and            
          the fair market value of the donated Los Angeles and Chicago                
          newspapers.  Valuation is an approximation derived from all the             
          evidence.  See Helvering v. Safe Deposit & Trust Co., 316 U.S.              
          56, 66-67 (1942); Silverman v. Commissioner, 538 F.2d 927, 933              
          (2d Cir. 1976), affg. T.C. Memo. 1974-285; Estate of Davis v.               
          Commissioner, 110 T.C. 530, 537 (1998).  The opinions of experts            
          are admissible and relevant to the issue of value, but the                  
          opinions must be weighed in light of each expert’s qualifications           
          and all other relevant evidence of value.  See Johnson v.                   
          Commissioner, 85 T.C. 469, 477 (1985).  We are not bound by these           
          opinions and may reach a decision based on our own analysis of              
          all the evidence in the record.  See Helvering v. National                  
          Grocery Co., 304 U.S. 282, 295 (1938); Estate of Newhouse v.                
          Commissioner, 94 T.C. 193, 217 (1990).  We may accept the opinion           
          of an expert in its entirety, see Buffalo Tool & Die                        

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