- 43 -
relatively small in relation to the inventory carried by a movie
memorabilia store or chain of stores.14
A year to liquidate the collection at full retail store
prices would not be unreasonable under the circumstances. The
minimal physical storage requirements and comparatively stable
prices in the movie memorabilia market over the course of a year
support such a finding. Sec. 20.2031-2(e), Estate Tax Regs.
These same characteristics would also tend to minimize
carrying costs. There would be no additional marketing expenses
since such a store would already be in existence and the
collection would merely be an addition to existing inventory,
utilizing existing marketing techniques. Everett's estimate of a
year is also quite short in comparison to the periods of time far
exceeding a year that would be required to liquidate the estate
of an artist with a large body of work. See, e.g., Calder v.
Commissioner, supra at 725-726 (period of up to 22 years to
liquidate collection); Estate of O'Keeffe v. Commissioner, supra
(more than 10 years to sell entire collection).
It would also be inappropriate to discount the collection as
we did the donation of thousands of duplicate copies of Yiddish
sheet music in Rimmer v. Commissioner, supra, or the large number
of donated books in Skripak v. Commissioner, 84 T.C. 285, 324
14 There are 7,378 items in the collection. Everett
testified that his three stores carry in excess of 3 million
items in inventory. His personal collection was even larger than
that.
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