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limited analysis of his valuation of the “Stories of the Bible”
book sets and no analysis of his valuation of the religious
articles.
We reject Malina’s opinion because he gave no persuasive
explanation of his methodology, made no reference to comparable
sales or a valuation rationale, and made no reference to any
experience he had that would support the values at which he
arrived. Without any reasoned analysis, his report is useless.
His opinions are so exaggerated that his testimony is not
credible. See Dean v. Commissioner, supra. The record is devoid
of any evidence of actual sales of any of the Kesslers or other
objective evidence supporting the values claimed by Malina and
petitioner or any substantial values for the contributed
property.
Moreover, the fair market values at which Malina arrived are
contradicted by the objective evidence in this case. Petitioner
argues that we should rely on his representations of the value of
the Kesslers because he examined the market for Kesslers. He
recalled no details of his alleged activity in this regard,
however. We are not required to accept petitioner’s testimony
and, under all of the circumstances, conclude that it is unworthy
of belief. The contributed property was stored in boxes on
pallets for many years in a bakery warehouse that only had
limited security. The warehouse had a rodent problem and was
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