Gerald D. and Catherine Leibowitz - Page 52

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          from Rothschild and the Appraisers Association of America gave              
          petitioner no reason to doubt either the competence of Messrs.              
          Rothschild and Rose or their independence from each other at the            
          time of the appraisals.  Additionally, petitioner availed himself           
          of information supplied by AMMI, published sources of market                
          data, and his personal knowledge as a collector.  In sum, these             
          actions satisfied the requirement of a good faith investigation.            
          Because both conditions under section 6659(f)(2) have been                  
          satisfied, we find for petitioners on this issue.  Sec. 6659(e).            
               To reflect the foregoing,                                              


                                             Decision will be entered under           
                                        Rule 155.                                     
























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