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that he was wrong in concluding that the assembled value of the
coin ledgers could not have been double the value of either half.
Assuming that the value of the Brand Archive is attributable
principally to its content, as Robinson asserted, there were at
least two sets of the information constituting the content of the
coin ledgers in existence in 1983. Both the purchased set (the
Horace ledger set) and the set petitioners already owned before
the purchase were “mixed” sets, each being one-half of the
original ledgers and photocopies. Nevertheless, petitioners paid
$22,550 for the Horace ledger set, and Robinson accepts that
value as being its fair market value in 1983. If a third party
had purchased the Horace ledger set for $22,550 at a public
auction, we believe that the fair market value of petitioners'
set immediately after the auction would also have been $22,550,
based on the recent sales price of a comparable item. Thus
petitioners had two equivalent mixed sets of information that,
together, by the evidence available to us, and based on
Robinson’s analysis, could be worth double.
D. Discussion
In 1981, petitioners believed that Armin’s half of the coin
ledgers and photocopy, the Chicago Coin Co. papers, the Virgil
Brand estate papers, Armin's papers, and the Jane Allen papers
had no market value and, on that basis, they did not report them
on the estate tax return. Two years later, they paid $22,550 for
the Horace ledger set. We accept the implicit conclusion of the
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