Bruce and Jeanne Korson, et al. - Page 14

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          that he was wrong in concluding that the assembled value of the             
          coin ledgers could not have been double the value of either half.           
          Assuming that the value of the Brand Archive is attributable                
          principally to its content, as Robinson asserted, there were at             
          least two sets of the information constituting the content of the           
          coin ledgers in existence in 1983.  Both the purchased set (the             
          Horace ledger set) and the set petitioners already owned before             
          the purchase were “mixed” sets, each being one-half of the                  
          original ledgers and photocopies.  Nevertheless, petitioners paid           
          $22,550 for the Horace ledger set, and Robinson accepts that                
          value as being its fair market value in 1983.  If a third party             
          had purchased the Horace ledger set for $22,550 at a public                 
          auction, we believe that the fair market value of petitioners'              
          set immediately after the auction would also have been $22,550,             
          based on the recent sales price of a comparable item.  Thus                 
          petitioners had two equivalent mixed sets of information that,              
          together, by the evidence available to us, and based on                     
          Robinson’s analysis, could be worth double.                                 
               D.  Discussion                                                         
               In 1981, petitioners believed that Armin’s half of the coin            
          ledgers and photocopy, the Chicago Coin Co. papers, the Virgil              
          Brand estate papers, Armin's papers, and the Jane Allen papers              
          had no market value and, on that basis, they did not report them            
          on the estate tax return.  Two years later, they paid $22,550 for           
          the Horace ledger set.  We accept the implicit conclusion of the            



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