- 26 - with extensive experience dealing in collections similar to the Los Angeles and Chicago newspaper collections. Additionally, he has experience in the retail sale of birthday and anniversary newspapers. For the years before those in issue, petitioners claimed the following charitable contribution deductions for the Los Angeles and Chicago newspapers: Year Amount 1991 $144,448 1992 42,738 Total 187,186 Therefore, unless the fair market value of the newspapers as of January of 1991, was greater than $187,186, petitioners are not entitled to charitable contribution deductions for 1993 or 1994. After reviewing the reports and testimony of the experts, and based on all the evidence in the record, we believe that Mr. Hughes’ appraisal considered the relevant factors for purposes of valuing the newspaper collection, and his valuation determination reflects the approximate value of the collection.24 Accordingly, we hold that petitioners are not entitled to charitable 24We note that, in this situation, it is sufficient that we find, as we have, that the fair market value of the newspapers as of January of 1991 was not in excess of the amount of charitable contribution deductions that petitioners took for the newspapers in previous years. See, e.g., Hamm v. Commissioner, 325 F.2d 934, 939-940 (8th Cir. 1963), affg. T.C. Memo. 1961-347; Rimmer v. Commissioner, T.C. Memo. 1995-215.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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