- 10 - 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 concernsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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