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charitable organization under section 170(c), of the above-
described materials that petitioner received from the Government
during the preparation of McVeigh’s legal defense.
On May 1, 1998, John R. Payne (Payne), employed by
petitioners to value the materials for the purpose of their
claiming a charitable contribution deduction, appraised the
materials at $294,877. Payne spent only one day reviewing the
materials, which included hundreds of thousands of items
contained in 171 boxes. He reviewed only a small percentage of
the materials before assessing their value. Although he
discounted his preliminary value assessment by 50 percent because
none of the materials were originals, Payne did not take into
consideration that multiple copies of the materials had been
distributed to various attorneys during the course of the
underlying trial. Payne’s appraisal method in part involved
assessing the value of certain documents at the price that a
legal research service would charge for access to them. His
appraisal method also relied heavily on purchase prices or
assessed values of document archives that Payne considered to be
comparable collections. All of the collections to which Payne
compared the materials possessed by petitioner as part of
McVeigh’s case file, however, consisted primarily of original
documents, handwritten letters, and original signatures of
players in other infamous crimes or scandals. None of the
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