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