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          were also named as defendants in numerous lawsuits by investors             
          in Jackie Fine Arts tax shelters.7                                          
               We reject both the Rose and the Rothschild appraisals, which           
          exceed by more than 20 percent the values asserted by                       
          petitioner’s expert at trial.  The record fails to support either           
          of these appraisals.                                                        
               Nothing in the record supports an inference that, at the               
          time petitioner engaged the two appraisers, he could have                   
          reasonably known of their role in marketing the Jackie Fine Arts            
          tax shelter.  Petitioner did not obtain the appraisals from                 
          Messrs. Rose and Rothschild with intent to inflate the value of             
          his charitable contribution for the gift of the collection to               
          AMMI.                                                                       
               Petitioner retained Morris Everett (Everett) to appraise the           
          collection and to prepare an expert report for trial.  At the               
          time of trial, Everett had been a collector of movie memorabilia            
          for over 30 years and a dealer since 1984.  He opened his first             
          retail store in Cleveland, Ohio, in 1987, and later opened other            
          stores in Hollywood and New York City.                                      
               Everett based his valuation of the collection on the                   
          prevailing 1985 prices in the retail store and catalog sales                
               7 See, e.g., Faircloth v. Finesod, 938 F.2d 513 (4th Cir.              
          1991); Mechigian v. Art Capital Corp., 612 F. Supp. 1421                    
          (S.D.N.Y. 1985); Ross v. Jackie Fine Arts, Inc., No. C/A 2:85-              
          2425-1 (D.S.C. 1991); Daggett v. Jackie Fine Arts, Inc., 733 P.2d           
          1142 (Ariz. Ct. App. 1986).                                                 
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