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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
market.
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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