Jerrold E. and Helen C. Arbini - Page 24

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          property22 and how the property is used by the donee.23  See Lio            
          v. Commissioner, 85 T.C. at 71; Chiu v. Commissioner, 84 T.C.               
          722, 734-736 (1985); Skripak v. Commissioner, 84 T.C. at 322.               
               It is unrealistic to assume that multiplying an average                
          price of $35 by the 33,710 issues contained in the bound volumes,           
          and then placing an additional value on the Sunday comic and                
          daily comic strip sections contained therein, accurately measures           
          the fair market value of the Los Angeles and Chicago newspapers.            
          Even Mr. Verb admitted that he would not purchase the Los Angeles           
          and Chicago newspapers based on a price of $35 per issue.  It               
          would involve an enormous amount of time, expense, and effort to            
          sell each of the 33,710 issues.  At trial, respondent’s expert              
          testified that it would take over 100 years to sell each issue              
          individually.  Mr. Verb could not estimate the amount of time it            
          would take to sell each issue individually.  Additionally, the              
          33,710 issues were in firmly bound volumes.  The binding would              


               22The Los Angeles and Chicago newspapers were evenly                   
          exchanged for the Montana newspapers, which were purchased in               
          1988 for $1,750.  We note that the Montana newspapers were not              
          insured during storage or during delivery to Mr. Berglas, despite           
          the fact that they were evenly exchanged for the Los Angeles and            
          Chicago newspapers which petitioners claim were worth                       
          approximately $1.5 million.                                                 
               23In 1998, the SFACA sold its entire collection of                     
          newspapers, of which the Los Angeles and Chicago newspapers                 
          constituted a small portion thereof, to Ohio State University for           
          $100,000.  Petitioners do not dispute Mr. Hughes’ estimate that             
          the SFACA collection weighed over 75 tons and consisted of                  
          approximately 6,666 bound volumes containing approximately                  
          200,000 newspapers.                                                         




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