Thomas B. Drummond - Page 6

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          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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