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contributions (as defined in section 170(c)) made within the
taxable year. In general, the amount of a charitable
contribution made in property other than money is the fair market
value of the property at the time of the contribution. See sec.
1.170A-1(c)(1), Income Tax Regs. Fair market value is defined as
the price at which the property would change hands between a
willing buyer and a willing seller, neither being under any
compulsion to buy or sell and both having reasonable knowledge of
the relevant facts. See sec. 1.170A-1(c)(2), Income Tax Regs.
Fair market value is a question of fact to be determined from the
entire record. Skripak v. Commissioner, 84 T.C. 285, 320 (1985).
Under section 1.170A-13(c), Income Tax Regs., if a
contributed item is valued in excess of $5,000, the donor must
obtain a qualified appraisal for the contributed property, attach
a fully completed appraisal summary to the Federal income tax
return, and maintain reasonably detailed records containing a
description of the property, the fair market value of the
property at the time of the donation, the method used in
determining the fair market value, and the cost or other basis.
A qualified appraisal shall include, inter alia, a
description of the property in sufficient detail for a person who
is not generally familiar with the type of property that was
contributed, a description of the physical condition of the
property, the qualifications of the qualified appraiser, the
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