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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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