Bruce and Jeanne Korson, et al. - Page 9

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          (1) the inadequacy of the auction process in general, (2) the               
          inadequacy of the particular auction at which petitioners bought            
          Horace's half of the coin ledgers, and because (3) the nature of            
          the Brand Archive was not fully understood in 1983.  He believes            
          that, in 1983, the full set of the coin ledgers had a                       
          “conservative” value of $150,000.  To reach his opinion, Austin             
          testified:  “In the rapidly rising, serious numismatic market               
          from 1983 to 1991 (and later), an extrapolation of three times              
          the 1983 value is highly conservative.  All other parts of the              
          archive aside, I believe a 1991 figure of $450,000 for the                  
          ledgers alone to be a fair market value.”                                   
               As to the Chicago Coin Co. papers, Austin based his                    
          valuation on a comparison to the New Netherlands Coin Co.                   
          auctioneer's books, which were sold at auction in 1991 for                  
          $20,900.                                                                    
                    2.  Analysis of Gabriel Austin’s Testimony                        
               We do not find Gabriel Austin’s testimony helpful in                   
          determining the fair market value of the coin ledgers on the                
          contribution date.  Austin failed to convince us that the value             
          of the coin ledgers was $450,000.                                           
               Austin’s testimony was vague and he did not make it clear to           
          us how he arrived at many of the figures he used in the various             
          stages of his analysis.  Where we do understand his analysis, it            
          is, for the most part, unpersuasive.  Austin starts with $22,550,           
          the price petitioners paid in 1983 for Horace’s half of the coin            



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