- 40 -
he concluded that it was inappropriate to take the aggregated
75-percent maximum discount. He took the aggregated 30-percent
minimum discount and reduced the aggregated unadjusted value of
the coins by this percent. He then increased the resulting value
by a small premium, which he concluded ranged from zero to 10
percent, to reflect the recognition of the decedent's name and
its connection to the collection. Mr. Rosen then reduced the new
amount by 7.5 percent to reflect Superior's auction fee. His
unadjusted total valuation for the 191 coins was $6,202,850.
After applying the aforementioned discounts, premium, and the
7.5-percent auction fee, Mr. Rosen concluded that the fair market
value of the 191 coins on the applicable valuation date was
$4,217,163.
The estate's second expert, Julian M. Leidman (Mr. Leidman),
has dealt in rare coins full-time for over 30 years. He is a
member of the American Numismatic Association and the
Professional Numismatists Guild. He was retained by the estate
to prepare five different appraisals of the subject coins. Four
of these appraisals, all of which are mentioned above in our
findings of fact, were for the 191 coins. For purposes of this
proceeding, Mr. Leidman valued the 191 coins at $3.78 million.
In so doing, he considered the decedent's contract to sell the
coins through Superior, a declining coin market, the large number
of pieces contained in the collection, the impact of flooding the
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