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of Iowa, Inc. v. Commissioner, 97 T.C. 496, 508 (1991); Parker v.
Commissioner, 86 T.C. 547, 562 (1986). Consequently, we will
consider the opinions of the two experts in their written reports
and testimony insofar as they help us determine the relevant
market and the appropriate methodology to be used in answering
ultimate question, the the fair market value of the collection.
IT&S of Iowa, Inc. v. Commissioner, supra; Chiu v. Commissioner,
84 T.C. 722, 734-735 (1985); see also Estate of Gray v.
Commissioner, T.C. Memo. 1993-334.
a. Petitioner's Experts
Petitioner initially obtained two appraisals of the
collection in order to ascertain the amount of their charitable
deduction. F. Peter Rose performed the appraisal of the
collection, which he valued at $188,085, that petitioners
ultimately used in preparing their 1985 income tax return.
Another appraisal was performed by Sigmund Rothschild, who valued
the collection at $186,575. Messrs. Rose and Rothschild
performed approximately 1,500 appraisals of “reproduction
masters” of works of art in connection with tax shelters marketed
by Jackie Fine Arts. Rose v. Commissioner, 88 T.C. 386, 398-399
(1987), affd. 868 F.2d 851 (6th Cir. 1989). Both Rose and
Rothschild, by reason of the inflated values in those appraisals,
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