- 44 -
and, even if we did, we are unable to ascertain the amount of any
future seller's commission with reasonable certainty. We hold
that the applicable value of the 191 coins is $7,635,000.
b. Thirty-Six Additional Coins
Respondent determined that the applicable value of the
36 additional coins was $816,300. Respondent's expert, Mr.
Conturi, valued these coins using the same methodology that he
employed to value the 191 coins. Mr. Conturi concluded that the
fair market value of the 36 coins was $609,770 on the alternate
valuation date. Respondent concedes that the value of these
36 coins is no higher than Mr. Conturi's valuation.
The estate asserts that the fair market value of the
36 coins was $274,650. Mr. Leidman valued 35 of these coins, and
his analysis generally parallels his analysis for the 191 coins.
He testified that 35 of the 36 coins had a fair market value of
$274,650 on the alternate valuation date; neither he nor the
estate addressed the value of the 36th coin at trial.
We have the same inherent problems with the experts'
valuations of the 36 additional coins, as we did with their
valuations of the 191 coins. We reject both of their opinions.
We are uncomfortable, however, with the value ascribed to these
coins by respondent. Accordingly, we proceed to value the coins
based on the record at hand. Although the decedent did not value
the 36 additional coins, he did value the 191 coins mentioned
Page: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 NextLast modified: May 25, 2011