- 7 - “The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.” Sec. 1.170A-1(c)(2), Income Tax Regs. III. Value of the Contribution A. Introduction To support their respective valuations, the parties rely principally on the testimony of expert witnesses. We have considered that testimony and, in part, have relied on it in making our finding. B. Petitioners’ Expert 1. Gabriel Austin’s Testimony Gabriel Austin (Austin), petitioners’ expert witness, is an appraiser and cataloguer who was accepted by the Court as an expert in the valuation of archives, books, and manuscripts. Austin prepared a written report for submission to the Court as his expert testimony (the Austin report). In the Austin report, Austin expresses separate opinions as to the values on the contribution date of (1) the coin ledgers, (2) the Chicago Coin Co. papers, (3) the Virgil Brand estate papers, (4) Armin's papers, and (5) the Jane Allen papers. Based on Austin’s failure to comply fully with the standards of Rule 143(f) with respect to expert witness reports, those portions of the Austin report expressing opinions as to the values of the Virgil Brand estatePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011