Gerald D. and Catherine Leibowitz - Page 3

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               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits are incorporated             
          herein by this reference.  At the time of filing their petition,            
          petitioner and Catherine Leibowitz were married and resided in              
          Fresh Meadows, New York.  Petitioner has a Ph.D. in clinical                
          psychology from the University of Rochester.  In 1985, he                   
          maintained a private practice and served as chief psychologist at           
          a handicapped children's residential center.                                
               Petitioner's interest in movie memorabilia began in                    
          childhood, stimulated in part by his father's employment on the             
          business side of the movie industry.  Over the years, petitioner            
          had collected a large number of 8- by 10-inch black and white               
          still photographs.  In the 1970's, petitioner began collecting              
          print blocks, which are the metal plates used to print newspaper            
          advertisements.  At some time in the early 1980's, petitioner               
          acquired the bulk of the collection, including all the posters,             
          from a family friend, Robert Schwartz, who had worked for United            
          Artists.  Schwartz had assisted petitioner in collecting the                
          print blocks.  At no time in 1985 or in prior years was                     
          petitioner a dealer in movie memorabilia.  Prior to donating the            
          collection to AMMI, petitioner had never sold or otherwise                  
          disposed of any part of the collection or other movie                       
          memorabilia.                                                                








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