Jerrold E. and Helen C. Arbini - Page 14

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               Respondent argues that the fair market value of the Los                
          Angeles and Chicago newspapers in the wholesale market at the               
          time of the donation was $14,271.12  Respondent relies on the               
          report and testimony of Timothy Hughes (Mr. Hughes) to establish            
          the fair market value of the newspapers.  Mr. Hughes started in             
          the rare newspaper business in 1976 and currently maintains an              
          inventory of over one million newspapers dating from 1550 through           
          1993.  He publishes six catalogs per year containing listings of            
          historic newspapers for sale, and he also maintains a website               
          listing newspapers for sale.  Mr. Hughes has spent more than 23             
          years working to establish a mailing list of newspaper collectors           
          and as of December 1998, he had 755 active buyers on the mailing            
          list.  Mr. Hughes regularly buys and sells newspaper collections            
          and also provides individual issues for sale to retail customers.           
          He is a member of the board of advisers of Warman’s Americana &             
          Collectibles price guide, a reference source for American                   
          collectibles, and produces the annual price list for early and              
          rare newspapers found in the guide.  Mr. Hughes has provided                
          consulting services, including valuations, to (1) the Newseum,13            
          (2) Sotheby’s and Christie’s auction firms in New York City, and            
          (3) leading book and autograph dealers.                                     

               12Thus, the value of petitioners’ 50-percent interest in the           
          newspapers at the time of the donation would have been $7,135.50.           
               13The Newseum is a media museum located in the Washington,             
          D.C., metro area, which contains newspaper exhibits.                        

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