- 41 - proper market, retail stores, to value the collection. The record also contains sufficient evidence to enable us to work back from Everett's figures to arrive at a reliable independent valuation for all but three categories of memorabilia in the collection. a. Blockage Discount Once a proper market is selected, individual items in a charitable contribution are to be valued individually, and not in bulk. Sec. 20.2031-1(b), Estate Tax Regs. However, where a block of property could not be sold on the valuation date or within a reasonable period thereafter without affecting market price, the Court must apply a “blockage” discount. Richardson v. Commissioner, 151 F.2d 102, 103 (2d Cir. 1945), affg. a Memorandum Opinion of this Court dated November 30, 1943. This Court has applied blockage discounts to estates of artists that contain large numbers of the artist's own works for which there is only a limited market because of the nature of the art. Calder v. Commissioner, 85 T.C. 713, 722-723 (1985) (blockage discount applied to six simultaneous gifts of large number of works by one artist); Estate of Smith v. Commissioner, 57 T.C. 650, 658 (1972), affd. 510 F.2d 479 (2d Cir. 1975) (blockage discount applied where estate contained 425 pieces and record showed that artist's works appealed to relatively small group of willing buyers); see also Estate of O'Keeffe v. Commissioner, T.C. Memo. 1992-210. The Court has also applied a blockagePage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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