-13-
another ground 815 F.2d 32 (6th Cir. 1987); Estate of Shlensky v.
Commissioner, T.C. Memo. 1977-148 (15-month window).
As fair market value is a factual determination and
necessarily inexact, evidence of the price obtained at a recent
arm’s-length sale may be extremely probative. See Estate of
Keitel v. Commissioner, T.C. Memo. 1990-416 (citing Ambassador
Apartments Inc. v. Commissioner, 50 T.C. 236, 244 (1968), affd.
per curiam 406 F.2d 288 (2d Cir. 1969); Messing v. Commissioner,
48 T.C. 502, 512 (1967); Estate of Schroeder v. Commissioner, 13
T.C. 259, 263 (1949)). The weight given to an actual sale price
is greatly diminished, however, where a material change in
circumstances occurs between the valuation date and the date of
sale. See Estate of Spruill v. Commissioner, 88 T.C. 1197, 1233
(1987).
We find that petitioners’ purchase through TRY of the
subject property for $75,000 is persuasive evidence of the fair
market value of the subject property. Petitioners were willing
buyers, and the Monks Nonprofit through Father Stevens was a
willing seller. Petitioners’ purchase of the subject property
was also within a reasonable time, approximately 17 months,
before the donation to the charitable organization. Further,
there is no evidence of a material change in the subject property
between the valuation date and the date of purchase that would
cause us to diminish the weight of this evidence. In fact, very
few alterations, only general cleaning and repair-type
improvements, were made to the subject property in the
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