Roger and Sharon Wortmann, et al. - Page 12

                                        -12-                                          
               While fair market value is a question of fact to be                    
          determined from the entire record, we were presented with four              
          valuations of the subject property.  See Zmuda v. Commissioner,             
          79 T.C. 714, 726 (1982), affd. 731 F.2d 1417 (9th Cir. 1984).               
          Three find fair market values of the subject property that are              
          close to one another, approximating $75,000, while one valuation,           
          which appraisal analysis and methodology we find troubling, is an           
          outlier.  We consider and evaluate each of these value                      
          determinations in turn.  We first address the purchase of the               
          subject property by petitioners, through TRY, on May 22, 1997,              
          just 17 months before TRY contributed it to a qualifying                    
          charitable organization on October 29, 1998.                                
               A.  Prior Sale of the Property                                         
               We note that evidence of what property sold for within a               
          reasonable time before the valuation date generally is competent,           
          substantial, and persuasive evidence of its fair market value on            
          the valuation date.  Douglas Hotel Co. v. Commissioner, 190 F.2d            
          766, 772 (8th Cir. 1951), affg. 14 T.C. 1136 (1950).  Actual                
          sales between a willing buyer and a willing seller are generally            
          more reliable than estimates and approximations and indicate what           
          a hypothetical buyer and seller may agree on.  Estate of Hall v.            
          Commissioner, 92 T.C. 312, 338 (1989).  Windows of time between             
          the valuation date and the sale date have been found to be                  
          reasonable under some circumstances, even when they are as long             
          as 15 months or 2 years.  See, e.g., Estate of Kaplin v.                    
          Commissioner, T.C. Memo. 1986-167 (2-year window), revd. on                 





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