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               Sellers who sold large quantities in bulk at conventions               
          also tended to be selling at distress prices, even below the                
          values in Warren's report.  A sale at distress prices indicates a           
          seller under compulsion or a bulk sale.  The regulation does not            
          permit either circumstance to dictate valuation.  Sec. 20.2031-             
          1(b), Estate Tax Regs.                                                      
               In 1985, stores specializing in movie memorabilia were                 
          located in such major metropolitan areas as New York, Los                   
          Angeles, and San Francisco.  These stores also competed in                  
          nationwide markets through catalog sales along with dealers who             
          specialized in catalog sales.  Despite the lack of specific                 
          comparative sales data in the record concerning the different               
          markets, we conclude that it is more likely than not, based upon            
          the testimony of both experts, that retail stores were the most             
          common form of sale to “ultimate consumers” of movie memorabilia            
          in 1985.                                                                    
               The mint condition of the collection particularly suited it            
          to sale on consignment in the retail store setting or in the                
          catalog sales market.  The absence of “high end” titles would               
          have precluded sale of most of the collection on an item-by-item            
          basis in the auction market.  These factors support our ultimate            
          finding that, in December 1985, retail stores were the relevant             
          market for the Leibowitz collection.  We therefore reject                   
          Warren's overall valuation of the collection.                               
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