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aggregated unadjusted value to reflect four discounts and one
premium. The first discount, he testified, was a tainted status
discount that takes into account the market's awareness that the
second grading by NGC was on the high side and that the initial
grading by PCGS was arguably the more reliable of the two
gradings. The second discount, he testified, was a blockage
discount that takes into account his belief that the market will
react negatively to a sale of a large collection of coins at one
time. The third discount, he testified, was a market factor
discount that takes into account his belief that the rare coin
market was in a poor state on the applicable valuation date and
that dealers were reluctant to buy gold coins except at bargain
basement prices. The fourth discount, he testified, was a
contracts/low bids discount that takes into account his belief
that Superior's contractual right to sell the coins at auction
would have a depressing effect on their values. Mr. Rosen
testified that the Superior contract and the sale of all coins at
one time would potentially foster a prearranged bidding scheme
whereby buyers would deliberately bid low.
Mr. Rosen established a range for each discount: 10 to 20
percent for the tainted status discount; 10 to 25 percent for the
blockage discount; 10 to 15 percent for the market factor
discount; and zero to 15 percent for the contracts/low bids
discount. Acknowledging that his discounts overlapped somewhat,
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