Bruce and Jeanne Korson, et al. - Page 7

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          “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 estate             



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