Jerrold E. and Helen C. Arbini - Page 12

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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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