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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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