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discount to a charitable donation of a collection of Yiddish
sheet music, obtained in a single bulk purchase, containing
hundreds of identical copies that would have depressed prices if
they had been sold. See Rimmer v. Commissioner, T.C. Memo. 1995-
215 (85,000 pieces of 650 separate titles in a declining market).
Blockage discounts--if appropriate to the particular facts in the
case--apply to donations to museums. Estate of O'Keeffe v.
Commissioner, supra. Determination of a reasonable period of
time “depends on all the facts and circumstances”. Estate of
Sawade v. Commissioner, T.C. Memo. 1984-626, affd. 795 F.2d 45
(8th Cir. 1986). Periods of up to a year have been found to be
reasonable, id., although such periods may be much shorter if
factors such as market volatility and time limitations so
dictate.
The parties' experts differed on the amount of time that it
would take to sell the collection. Warren postulated a period of
no less than 1 to 2 years because of the difficulties attendant
in gaining access to the market. However, Warren did not
consider how long it would take a skilled dealer in movie
memorabilia already present in the retail store market to sell
the collection. Bull v. Smith, 119 F.2d 490, 492 (2d Cir. 1941).
Everett estimated that the collection could be sold on
consignment in a retail store within a year without affecting the
prices obtained for each individual item. The collection was
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