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described as being extremely hot during the summer. The
contributed property was not insured, nor was any special
precaution taken to preclude loss due to deterioration, theft, or
fire. Petitioner’s contemporaneous conduct renders implausible
his claim that the property had substantial value. See Chiu v.
Commissioner, supra at 736. The only evidence of subsequent
handling of the contributed property suggests that it had little
value. See Skripak v. Commissioner, 84 T.C. at 322-323. If the
contributed property had a value of $949,030 or anything
approaching that value, as petitioner claims, petitioner would
have treated it with more care.
Respondent’s expert, Schmid, has been involved with stamps
on a full-time basis for 32 years. His experience includes
retail and auction sales, and he has authored two books on the
authentication of U.S. stamps. At the time of the trial, Schmid
was the owner of Colorano, a major publisher of first day covers
in the United States. Schmid provided a careful explanation
supporting his opinions of value.
Schmid described the pricing structure of first day covers
within the primary and secondary markets and indicated that the
prices of first day covers were in the following ranges:
Primary Market Secondary Market
Retail $1.00 - $3.00 $0.35 - $2.00
Wholesale 0.65 - 1.65 0.15 - 0.35
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