- 41 -
market, and the period of time in which the coins were to be
sold. He also assumed that the coins would be sold as a
collection and not individually. He contended that a 20-percent
blockage discount was warranted, but did not ascertain such a
discount separately because he inherently factored this discount
into his analysis.
Although we find the experts helpful to our understanding of
the world of numismatics, we find none of them helpful to our
determination of the fair market value of the 191 coins. Mr.
Conturi ascertained the fair market value of the 191 coins based
on the grades assigned by NGC, and he gave no consideration to
PCGS' grades, which were the lower of the two gradings. Mr.
Rosen failed to consider market factors in reaching his
conclusion of the coins' unadjusted value, and he took into
account novel discounts which are not recognized for Federal tax
purposes. His tainted status discount, for example, rests on
assumptions that we do not find to be valid on the facts herein.
This is also true for his market factor and contracts/low bid
discounts. With respect to the contract/low bid discount, in
particular, auctions are an appropriate and often used means of
presenting and selling rare coins. We do not see how an auction
sale would have a depressing effect on the sale prices of the
decedent's coins. As to the blockage discount, a blockage
discount typically reflects the depressing effect of placing a
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