Bruce and Jeanne Korson, et al. - Page 10

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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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