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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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