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have the time, inclination, expertise or capital to buy a
tract of land 10 or 20 times as big as the one he wants,
with a view to subdivision and sale of the excess." Id.
The above cases may be contrasted with Goldman v.
Commissioner, 388 F.2d 476 (6th Cir. 1967), affg. 46 T.C.
136 (1966), in which the fair market value of 151 bound
volumes of medical journals that had been contributed to a
hospital was at issue. The court held that the fair market
value should be computed "on the price an ultimate consumer
would pay", i.e., valued at retail, and further held that
"what might be paid by a dealer buying to resell is not a
proper consideration." Id. at 478. In Akers v.
Commissioner, 799 F.2d at 247, the court reconciled that
case with the others by noting that, unlike the unmounted
gems in Anselmo and unlike the undivided land in Akers, the
medical journals in Goldman "had already been 'subdivided,'
in effect" and "were ready for immediate sale in the retail
market and were not so expensive as to suggest that no
retail buyer for them could have been found."
The appropriate market for estimating the value of an
item of property may sometimes be the market in which the
taxpayer purchased the property. For example, in Lio v.
Commissioner, 85 T.C. 56 (1985), the taxpayers purchased
large quantities of lithographs and donated them to a
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