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ledgers with the accompanying half of the photocopy and a
photocopy of the Chicago Coin Co. papers. He attributes that
price to Horace’s half of the coin ledgers alone, without
accounting for the value, if any, of the two photocopies that
accompanied Horace’s half of the coin ledgers. To find the value
of the complete set of coin ledgers, he tripled the $22,550 and
somehow arrived at $75,000. He doubles that figure to account
for the inadequacy of the auction process in general, the unknown
importance of the coin ledgers, and the inadequacy of the
specific auction at which petitioners bought Horace's half of the
coin ledgers. We can understand (but do not necessarily agree
with) his adjustment for the general and specific alleged
inadequacies of the auction, see, e.g., Berry Petroleum Co. &
Subs. v. Commissioner, 104 T.C. 584, 637-638 (1995) (“prices
obtained at forced sales, at public auctions, or in restricted
markets may not be the best criteria of value”), but do not
understand his adjustment for the unknown importance of the coin
ledgers. Reasonable knowledge of relevant facts is part of the
applicable definition of fair market value. See sec. 1.170A-
1(c)(2), Income Tax Regs. If Austin’s adjustment to take account
of the unknown importance of the coin ledgers simply reflects the
fact that the coin ledgers might turn out to be more valuable
once their importance became known, we do not see how it affects
their fair market value before their importance became known.
Austin did not apportion the relative influence of the concerns
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