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Finding none of the experts helpful to our determination of
the coins' fair market value, we proceed to value the coins based
on the record at hand. We are guided by the decedent's valuation
of the subject coins. The decedent was a noted collector, with
at least 20 years' experience in collecting and grading coins.
The record shows that he did an excellent job in ascertaining the
value of coins. He ascertained that the 201 coins sold at the
February 1992 auction were worth $2,598,000, and these coins sold
for approximately $2,628,730. The actual sales price differed by
less than 2 percent from the decedent's valuation of these coins.
The decedent valued the 191 coins at $7,635,000. Although
the estate presented some evidence of a "buyer's market", we find
that the economic downturn would not have materially affected the
sale of the 191 coins because they were part of a premier
collection. We also do not believe under the facts herein that a
reduction for an estimated seller's commission is warranted.
Under section 20.2053-1(b)(3), Estate Tax Regs., an item may be
deducted on an estate tax return though its exact amount is not
then known, provided it is ascertainable with reasonable
certainty and will be paid. The superior court rescinded the
contract with Superior under which Superior would receive a
7.5-percent seller's commission, and the 191 gold coins were
returned to the estate. We find no certainty that the estate
will sell the coins in the future under a commission arrangement,
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