- 31 - Everett also considered the desirability of the 659 titles in the collection, which he characterized as “middle of the road” rather than “high end”. He reported that prices for titles such as those in the collection appreciated rapidly during the 1970's and early 1980's and, in most cases, have not appreciated greatly since then.10 In making his valuation, Everett also took into account the overall mint condition of the United Artists movie memorabilia in the collection. Everett took into account the development of the market throughout the mid-1980's up through 1987 because he believed that it was developing slowly throughout that period. He took into account in his report events that occurred both prior to and shortly after the donation when he valued the collection.11 9(...continued) meant to characterize the “average value” as a base price for items in the collection in a particular category. 10 Warren, respondent's expert, asserted that prices for movie memorabilia rapidly went up in all categories during the period 1986 to 1995, sometimes as much as 50 times or more. A comparison of prices in the 1985 price guides, see supra note 8, to the prices listed in the 1994 price guides that were also in evidence shows that the 106 items in the reference sample appreciated somewhere between 0 and 100 percent between 1985 and 1994. 11 Normally, post-donation market events that are not foreseeable must be disregarded. However, prospective events may be referenced for the limited purpose of establishing what the willing buyer’s and seller's expectations were on the valuation date and whether those expectations were “reasonable and intelligent”. Estate of Gilford v. Commissioner, 88 T.C. 38, 52 (1987); Estate of Jephson v. Commissioner, 81 T.C. 999 (1983). (continued...)Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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