- 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 NextLast modified: May 25, 2011