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valid consents to extend the period of limitations until
December 31, 1993, for tax years 1985 through 1988. On
December 17, 1993, respondent mailed a statutory notice of
deficiency to petitioners for the tax years in question based
upon a determination that the fair market value of the collection
was $1,956 in December 1985. Petitioners filed a timely petition
with the Tax Court.
ULTIMATE FINDINGS OF FACT
1. In December 1985, the relevant market for the sale of
movie memorabilia was the retail store.
2. In 1985, the fair market value of the entire collection
was $50,412. The fair market value of the collection and of
each category of memorabilia in the collection is:5
4(...continued)
for that year.
Petitioners claimed an additional $60,000 to $65,000 in
deductions attributable to the carryover in tax years 1989 and
1990. Those years were barred from assessment by expiration of
the period of limitations.
5 These values are drawn from Tables 1 and 2 in the
appendix. Table 1 summarizes the values for each category of
movie memorabilia in the collection from the parties’ experts and
the Court’s independent valuation. Table 2 contains comparative
values drawn from the parties’ experts and the Court’s valuation
of 106 one-sheets for which the record contained retail sales
prices independent of either party’s expert’s valuation. This
reference sample formed the basis for the Court’s valuation. See
infra note 8 and notes 15-17 and accompanying text for further
explanation of the Court’s methodology.
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