- 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...)
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