- 110 -
F.2d 1208 (11th Cir. 1985), affg. 80 T.C. 872 (1983); cf.
United States v. Cartwright, supra at 551-552. In
identifying what market to use in estimating the value of
an item of property, we have looked to the regulations
promulgated under the estate and gift taxes, see sec.
20.2031-1(b), Estate Tax Regs.; sec. 25.2512-1, Gift Tax
Regs., which provide that the fair market value of an item
of property is the sales price of the item in the market
in which such item is "most commonly sold to the public."
See, e.g., Goldstein v. Commissioner, 89 T.C. 535, 544
(1987); Lio v. Commissioner, supra at 66; Orth v.
Commissioner, 813 F.2d 837 (7th Cir. 1987); Skripak v.
Commissioner, 84 T.C. 285, 321-322 (1985); Anselmo v.
Commissioner, 80 T.C. at 881-882.
In applying the estate and gift tax regulations to
ascertain the fair market value of an item of property
for purposes of computing the amount of a charitable
contribution deduction, the Court of Appeals in Anselmo
v. Commissioner, 757 F.2d at 1214, noted the following:
Rules governing valuations for charitable
contributions of property are distinguishable
from valuations in the estate and gift context
because the taxpayer has the opposite incentives
in the two situations: the taxpayer wants to
reduce the value of property for estate and gift
tax purposes but, as here, the taxpayer wishes
to inflate the value of property for charitable
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