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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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