We consulted the Federal Elections Commission's Campaign Guide for Corporations and Labor Organizations, updated in January, and here's what it has to say about in-kind contributions (see page 14):

* Services (such as advertising, printing or consulting) are valued at the prevailing commercial rate at the time the services are rendered (i.e., the amount that was paid or would have been paid for the services).

* Discounts are valued at the amount discounted (i.e., the difference between the usual and normal charge and the amount paid by the committee).

If a company sells an ad worth $167,000 for $65,000, then, that would be an in-kind contribution of $102,000. Corporate contributions to PACs are illegal under the campaign finance laws the Times itself has long championed: "Corporations and labor organizations are prohibited from making contributions in connection with federal elections," according to the FEC. (A corporation may set up and administer a "separate segregated fund," or a corporate PAC, which receives contributions from people associated with the company, but it may not contribute to its own SSF or any other federally registered PAC.)