- 9 - (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 coinPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011