- 28 - 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).Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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