- 24 - 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.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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