jSamuel Jacobson - Page 12




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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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