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for the Kesslers is misplaced. There is no evidence that any
sales took place at the prices listed in those periodicals. We
are convinced that 60,484 Kesslers would likely be sold, if at
all, only in a wholesale market.
Based on Schmid’s experience in stamp collecting and in the
first day cover market, his valuation of the Kesslers is the best
evidence we have of fair market value, and it supports
respondent’s determination.
Respondent presented no expert evidence of fair market value
for the religious articles, offering only evidence that they were
not treated as valuable by subsequent possessors of the articles.
Petitioner, however, failed to establish a fair market value in
excess of $12,973 for all of the contributed property.
Accordingly, we conclude that petitioner is not entitled to
deductions in excess of the amounts allowed by respondent.
Section 6651(a) Addition to Tax
Respondent determined that petitioner is liable for the
section 6651(a)(1) addition to tax for 1993. Section 6651(a)(1)
imposes an addition to tax for failure to file timely a return,
unless the taxpayer establishes that the failure did not result
from “willful neglect” and that the failure was due to
“reasonable cause”.
Petitioner failed to offer any evidence or explanation
regarding the late filing of his 1993 return. Thus, respondent’s
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