Jerrold E. and Helen C. Arbini - Page 23

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          individual issues would have to be removed from their bindings,             
          made available for presentation, and willing purchasers would               
          have to be located for each date in order for the entire                    
          collection to be sold.  An “ultimate consumer” would generally              
          not purchase an entire collection of 33,710 newspapers in bound             
          volumes, or even one bound volume, for the purpose of obtaining             
          one specific issue or comic strip.  We conclude that the ultimate           
          consumers of the bound newspapers in issue are newspaper                    
          collectors, newspaper dealers, and others interested in obtaining           
          a newspaper collection.  Accordingly, we hold that the                      
          appropriate market for purposes of determining the fair market              
          value of the Los Angeles and Chicago newspapers is the wholesale            
               After identifying the appropriate market, fair market value            
          is determined by the amount that consumers would pay, in this               
          market, for the items in question on the date of contribution.              
          See Goldstein v. Commissioner, 89 T.C. at 544.  Relevant                    
          considerations include the amount that the taxpayer paid for the            

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