Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek - Page 42

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          large block of stock on the open market for sale at one time.               
          See sec. 20.2031-2(e), Estate Tax Regs.; see also Estate of                 
          Sullivan v. Commissioner, T.C. Memo. 1983-185.  Even if we were             
          to assume that such a discount applied to the rare coin market,             
          which we do not find to be a valid assumption under the facts               
          herein, the discount would be inapplicable here because the                 
          Trompeter Collection was an impressive collection with many                 
          unique coins.  The market would have been able to handle all                
          191 coins, as evidenced by the fact that 96.2 percent of the                
          decedent's 209 coins auctioned at the first auction sold there              
          for an aggregate price that approximated the aggregate value                
          calculated by the decedent.                                                 
               Nor do we find Mr. Leidman helpful to our determination of             
          the coins' fair market value.  He valued the 191 coins at $3.78             
          million based on the assumption that the coins would be                     
          liquidated because they had to be sold.  In making such an                  
          assumption, Mr. Leidman admittedly disregarded the mandate of               
          section 20.2031-1(b), Estate Tax Regs., that "fair market value             
          * * * is not to be determined by a forced sale price".10  He also           
          assumed inappropriately that the coins would be sold as a group             
          and not individually.                                                       



               10 Mr. Leidman acknowledged on cross-examination that the              
          191 coins would be worth $8.5 million if the compulsion aspect              
          was removed.                                                                




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