Jerrold E. and Helen C. Arbini - Page 26

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          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.                                       




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