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Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980), or we
may be selective in the use of any portion, see Parker v.
Commissioner, 86 T.C. 547, 562 (1986).
Petitioners argue that the fair market value of the Los
Angeles and Chicago newspapers in the retail market at the time
of the donation was $1,549,796.50 and that petitioners’
charitable contribution is $774,898.10.9 Petitioners rely on the
reports and testimony of their expert, Mr. Verb. Mr. Verb’s
qualifications for valuing the newspapers includes: (1) Flea
market experience; (2) operation of a comic book store from 1971
to 1975; (3) attendance and participation in comic conventions
since the early 1970's; and (4) sales at collectibles conventions
since the early 1970's. Mr. Verb’s experience in selling
newspapers is limited to individual sales in the retail market,
and he testified that he had no experience in dealing with a
collection of newspapers containing over 30,000 issues.
Mr. Verb computed the value of the newspapers by determining
the average retail price for one individual issue and then
multiplying that price by the total number of newspapers.
9Mr. Verb determined, and petitioners originally argued,
that the overall value of the donated newspapers was
$1,606,797.50, and that petitioners’ charitable contribution was
$803,398.75. In their reply brief, petitioners concede that they
overvalued the newspapers because they did not account for the
fact that the Sunday comics were printed on both sides of the
newspapers; thus, their value was only one-half of the amount
attributed to them by Mr. Verb.
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