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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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