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Mr. Hughes felt that willing buyers of the Los Angeles and
Chicago newspapers included newspaper collectors, newspaper
dealers, book dealers, magazine dealers, and others who had a
serious interest in newspaper collections. Mr. Hughes valued the
newspapers according to condition, content, and date and title.
Mr. Hughes looked at comparable sales of newspaper collections
that he had purchased for his business to aid in determining the
fair market value of the newspapers.14 He used the comparable
sales as a guideline to determine an annual price for the
newspaper runs based on their time period. Mr. Hughes also
relied on prices contained in Warman’s Americana & Collectibles
price guide, for which he annually produces the price list for
early and rare newspapers. In assigning a price to annual runs
of newspapers contained in the collection, Mr. Hughes accounted
for the fact that newspaper runs from certain years or time
14Generally, comparable sales of similar properties that are
reasonably proximate in time represent the best evidence of fair
market value. See Estate of Spruill v. Commissioner, 88 T.C.
1197, 1229 n.24, 1233 (1987); Estate of Rabe v. Commissioner,
T.C. Memo. 1975-26, affd. without published opinion 566 F.2d 1183
(9th Cir. 1977). The comparable sales relied upon by Mr. Hughes
occurred primarily in the years 1995 to 1997. In some cases,
sales that occurred during years other than those in issue are
helpful in determining fair market value because those sales may
indicate the fair market value for the years in issue. See
Estate of Spruill v. Commissioner, supra at 1233; Estate of
Gilford v. Commissioner, 88 T.C. 38, 52-55 (1987); Williford v.
Commissioner, T.C. Memo. 1992-450. Mr. Hughes justified his use
of comparable sales in later years by noting in his appraisal and
at trial that the fair market value of the newspapers has changed
very little from 1991 until the present.
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