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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 blockage
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