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(1985) (500,000 reprints of scholarly books donated in large,
coordinated program were worth only 20 percent of retail list
price). Only 546 of the 7,378 items in petitioner's collection
were duplicates, and generally there were no more than two to
three copies of any particular item. Furthermore, these items
had value in the marketplace because of the existence of an
active barter market where dealers, collectors, and museums could
trade. Contrary to respondent’s contention, the fact that AMMI
had not yet participated in that market at the time of trial,
albeit in part because of the pendency of this proceeding, is of
no moment in determining whether to value the duplicates at full
fair market value.
Based upon the foregoing considerations, we do not apply a
blockage discount to the fair market value of petitioner’s
collection.
b. Fair Market Value of the Collection
We recognize that valuation of property is an inexact
science. If the parties do not settle on a value, and neither
party's appraisal can be accepted, the Court can resolve it only
through “Solomon-like” pronouncements, Buffalo Tool & Die
Manufacturing Co. v. Commissioner, 74 T.C. at 452, based upon
evidence in the record.
We considered a number of factors in arriving at a fair
market value of the collection. The agreed mint condition of the
collection played a major role, both in determining the relevant
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