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experts that $22,550 reflects the fair market value of that
purchase. For reasons we have explained, we conclude that the
value in 1983 of the complete set of coin ledgers and the
photocopy was twice the then value of the Horace set, viz,
$45,100. We agree with what we take to be Robinson’s conclusion
that that value should be tripled to determine the value of the
sets on the contribution date, viz, $135,300. To that, we add
$7,350, Robinson’s value for the “remaining papers”, to arrive at
$142,650 as the total fair market value of the contribution on
the contribution date. Petitioners argue that we must take into
account the disability of the auction sale of the Horace set and
any increase in value that resulted from the enhancement of
Virgil Brand’s reputation. That may be so, but petitioners have
failed to provide us with any basis to quantify such factors. We
find that the value of the contribution on the contribution date
was $142,650.
III. Conclusion
We redetermine deficiencies in tax based on our finding as
to the value of the contribution on the contribution date; we
determine no overpayments.
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011