Sherrel and Leslie Stephen Jones - Page 6




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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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