- 32 -
b. Respondent's Experts
Respondent determined in the notice of deficiency that the
value of the collection at the time of the gift to AMMI was
$1,956. The report upon which that determination of value was
based was not made part of the record, and the record contains no
allocation of that amount among the various categories of movie
memorabilia in the collection. Respondent retained Jon R. Warren
(Warren) to determine the December 1985 fair market value of the
collection and prepare an expert report for trial. Warren also
testified at trial as respondent's expert. He is the author of
“Warren's Movie Poster Price Guide”, which was initially
published in 1986. Subsequent editions were published in 1993
and 1994. Warren also edits magazines devoted to movie
memorabilia, is a member of the International Appraiser's
Society, and is senior price editor for a major comic book
pricing guide. Warren began collecting memorabilia in 1976 and
began collecting movie memorabilia in 1980. During the mid-
1980's, Warren's movie memorabilia expertise was concentrated in
pre-1960 films. Warren became a dealer in movie memorabilia
after 1985. With subsequent editions of his book and other
business dealings, Warren has become a major dealer in movie
11(...continued)
We attach limited weight to post-1985 market events in this
case because we find that the “reasonable and intelligent”
expectations of a willing buyer and seller would be based
primarily on market conditions existing in 1985 and the years
prior thereto, and not on any prospective events.
Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 NextLast modified: May 25, 2011