- 34 - Warren considered the collection as a whole to have little intrinsic value because it consisted of “minor or unknown films released by United Artists”. He evaluated the collection as little more than a hoard, virtually unsalable within a short period of time, even at distress sale prices in the convention market. Warren also discounted the overall value of the collection because it consisted mostly of stills, pressbooks, and lobby cards, which he considered to be of the lowest value to a collector. Based upon these foregoing considerations, Warren assigned values as low as 25 cents to individual items. Warren’s base value for a one-sheet was $1. His highest single assigned value for a one-sheet was $75 for “Thunder Road”. Warren appraised the collection at the time of its donation to AMMI in 1985 at $5,733.49. 3. The Relevant Market Selection of the proper market for valuation purposes is a question of fact. Anselmo v. Commissioner, 757 F.2d at 1213. In determining the appropriate market to use in valuing most types of property, a sale “to the public” normally refers to a sale to the retail customer who is the ultimate consumer. Lio v. Commissioner, 85 T.C. at 70; Anselmo v. Commissioner, 80 T.C. at 882. A sale to an ultimate consumer is any sale to those persons who do not hold the item for subsequent resale. Goldman v. Commissioner, 388 F.2d 476, 478 (6th Cir. 1967), affg. 46 T.C. 136 (1966). However, when used in this context, the termPage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
Last modified: May 25, 2011