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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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