- 15 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011