Provide a written answer to the below Tax Research Problem.

RESEARCH PROBLEM (from South-Western Federal Taxation) Entire class Issue: Whether the taxpayer is entitled to a charitable contribution deduction for the donation of its clippings file to a qualifying charity at fair market value of $3,000,000 or at adjusted basis of $0.

(A Tax Court case decision is likely the authority needed. Of course, a court case may be the most appropriate authority when it interprets, for example, I.R.C. sections and has similar facts to the facts of the taxpayer in this Tax Research Problem.)

Facts: Taxpayer Falcon, a newspaper publisher, contributed its newspaper clippings file to a state historical society, a qualifying charitable organization under I.R.C. section 170(c)(2).