- 6 -
could be sold at auction for approximately $100,000 and expressed
an interest in auctioning it on his behalf.5 At or about the
same time, the curator of Italian drawings informed petitioner
that the National Gallery was interested in purchasing that
drawing. Petitioner advised her that Christie's could sell the
drawing in question at auction for $100,000 and that he would be
willing to sell it to the National Gallery for an amount exceed-
ing $100,000. Thereafter, petitioner received a letter from the
National Gallery offering to purchase the drawing in question for
$115,000. In January 1989, petitioner sold it to that museum for
that amount.
During all relevant periods, petitioner did not own or
acquire any drawings, other than the drawing in question, that
were either unattributed or misattributed and for which proper
attribution was obtained. During the 1970's, petitioner did not
attempt to sell any of the drawings that he had acquired during
those years. During the period 1985 through 1994, petitioner did
not sell any artwork or collectible, other than the drawing in
question. After the sale of the drawing in question, petitioner
did not use the proceeds from its sale to purchase other drawings
for purposes of attribution and sale.
Petitioner's Simplified Employee Pension
During 1989, petitioner informed his tax preparer, Thomas A.
5 At some time prior to 1982, petitioner attempted to sell the
drawing in question through Christie's. However, upon being
advised by Christie's that that drawing had a value of $500,
petitioner decided not to auction it at that time.
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