Bruce and Jeanne Korson, et al. - Page 12

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          has failed to aid us in determining the value of the coin ledgers           
          on the contribution date, and we accord his testimony no weight.            
               Austin’s total analysis leading to his opinion that the                
          Chicago Coin Co. papers were worth $20,000 in September 1991 is             
          as follows:  “These ledgers are comparable in value to the New              
          Netherlands Coin Company auctioneer's books; they differ in being           
          a record of an earlier period, and a record of the activities of            
          a private company.”  We fail to see the alleged correlation                 
          between the amount realized for the auctioneer's books and the              
          fair market value of the Chicago Coin Co. papers and therefore              
          attach little weight to Austin’s opinion with respect to the                
          value of the Chicago Coin Co. papers.                                       
               C.  Respondent’s Expert                                                
                    1.  Michael F. Robinson’s Testimony                               
               Michael F. Robinson (Robinson), respondent’s expert witness            
          is an appraiser and dealer in manuscripts, autographs, and rare             
          books, who was accepted by the Court as an expert in the                    
          valuation of manuscripts and rare books.  Robinson prepared a               
          written report that was received into evidence as his expert                
          testimony (the Robinson report).  Robinson is of the opinion that           
          the value of the Brand Archive on the contribution date was                 
          $75,000.  Robinson explains that $75,000 is (1) three times the             
          price paid for Horace’s half of both the coin ledgers and the               
          photocopy ($22,550 x 3 = $67,650) plus (2) $7,350 for “the                  
          remaining papers”.                                                          



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