jSamuel Jacobson - Page 11




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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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