Benjamin H. and Diane E. Robson - Page 8

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          specimen is harvested on a trip, the cost of the trip is prorated           
          over each specimen.  Mr. Perry then adjusts the values, based               
          upon factors such as the quality of the specimen and its rarity.            
          He believes that this is the only proper way to value animal                
          specimens, because he views each specimen as a unique object.               
               Replacement cost is a relevant measure of value where the              
          property is unique, the market is limited, and there is no                  
          evidence of comparable sales.  Estate of Palmer v. Commissioner,            
          839 F.2d 420, 424 (8th Cir. 1988), revg. 86 T.C. 66 (1986).  We             
          find, contrary to Mr. Perry's beliefs, that there is a market               
          throughout the United States for items comparable to those                  
          donated by petitioners.                                                     
               Petitioners argue that there are no comparable sales,                  
          because residents in California are prohibited from selling game            
          mounts.  We reject this contention.  Petitioners' argument, taken           
          to its logical conclusion, would result in their mounts' having             
          no value, as California residents could never sell them.                    
          Mr. Curry testified, however, that prices for game mounts in                
          California are equivalent to prices in States that do not place             
          restrictions on sales.  Thus, the restrictions imposed by                   
          California law do not materially affect the value of petitioners'           
          game mounts.  We therefore cannot accept Mr. Perry's valuations,            
          as petitioners have not demonstrated that their replacement cost            








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