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876, 894 (1971). Petitioners bear the burden of proof. Rule
142(a); Welch v. Helvering, 290 U.S. 111 (1933).
There is no disagreement that the donations were actually
made by petitioners. There is significant disagreement over the
value of the donated game mounts. Petitioners and respondent
presented expert testimony, and submitted expert reports,
concerning the value of these game mounts. The ultimate findings
of the respective experts are set out in the attached appendix.
Respondent primarily relies on the testimony of Alan Zanotti
(Mr. Zanotti). Mr. Zanotti founded his company, the African
Import Company, in 1986, after he determined that there was a
large supply of game mounts within the United States available
for sale. From the inception of his company to the present day,
Mr. Zanotti has sold between 3,500 and 4,000 game items. He
indicated that there was an active market for the items involved
in this case. Additionally, Mr. Zanotti has personally purchased
or sold many items similar to those donated by petitioners.
Mr. Zanotti believes that he would be able to assemble a collec-
tion comparable to petitioners' by purchasing items on the open
market. In fact, Mr. Zanotti currently has in his inventory many
of the same type of game mounts as those donated by petitioners.
Respondent submitted the report of another expert,
Herbert C. Curry (Mr. Curry). Mr. Curry is a special agent with
the Fish and Wildlife Service. Mr. Curry, a hunter and a collec-
tor of animal specimens, has extensive experience in investi-
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