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He also took into consideration the salability of the
Kesslers, noting that some of the pages would not be sold. He
proposed the following approach to valuing the Kesslers:
Percent
Sales Level Price of Lot Sales
High retail $2.00 5 $ 6,050
Low retail 0.35 10 2,118
High wholesale 0.35 10 2,118
Low wholesale 0.15 65 5,899
Unsalable -- 10 --
Total $16,185
Schmid indicated that these estimates are for a competitive
market. Schmid stated that a noncompetitive market would have
more “high retail” sales but would have fewer opportunities
overall for sales at all levels, resulting in a return in the
range of $15,000 to $20,000. He suggested that the bottom of
this range was more realistic based on his experience with
established dealers.
Schmid stated, however, that the most accurate valuation of
the Kesslers would be in the wholesale market where the Kesslers
would likely sell for $0.07 to $0.15 per page. Under this
assumption, the value of the Kesslers would be between $4,200 and
$9,000.
Petitioner challenges Schmid’s valuation of the Kesslers on
a wholesale basis because, he asserts, trade periodicals
indicated that a retail market existed for the Kesslers.
Petitioner’s reliance on trade periodicals to establish a market
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