- 12 - 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 - 0.35Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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