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has failed to aid us in determining the value of the coin ledgers
on the contribution date, and we accord his testimony no weight.
Austin’s total analysis leading to his opinion that the
Chicago Coin Co. papers were worth $20,000 in September 1991 is
as follows: “These ledgers are comparable in value to the New
Netherlands Coin Company auctioneer's books; they differ in being
a record of an earlier period, and a record of the activities of
a private company.” We fail to see the alleged correlation
between the amount realized for the auctioneer's books and the
fair market value of the Chicago Coin Co. papers and therefore
attach little weight to Austin’s opinion with respect to the
value of the Chicago Coin Co. papers.
C. Respondent’s Expert
1. Michael F. Robinson’s Testimony
Michael F. Robinson (Robinson), respondent’s expert witness
is an appraiser and dealer in manuscripts, autographs, and rare
books, who was accepted by the Court as an expert in the
valuation of manuscripts and rare books. Robinson prepared a
written report that was received into evidence as his expert
testimony (the Robinson report). Robinson is of the opinion that
the value of the Brand Archive on the contribution date was
$75,000. Robinson explains that $75,000 is (1) three times the
price paid for Horace’s half of both the coin ledgers and the
photocopy ($22,550 x 3 = $67,650) plus (2) $7,350 for “the
remaining papers”.
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