Jerrold E. and Helen C. Arbini - Page 25

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          have to be destroyed, and all the issues would have to be removed           
          in order to prepare individual issues for sale.  Mr. Verb                   
          testified that when he owned his store, he had to employ a person           
          part-time just to cut comic strips out of newspapers.  Finally,             
          the evidence in the record reflects that individual issues sold             
          to retail customers are usually packaged in some form of                    
          presentation folder.                                                        
               The value petitioners attribute to the newspapers fails to             
          account for relevant time and expense factors involved in selling           
          the newspapers in the retail market.  Petitioners rely on Mr.               
          Verb’s valuation which was simply based on determining the                  
          average retail price for an individual newspaper and multiplying            
          this price by the number of issues contained in the collection,             
          without consideration of other factors which would affect the               
          value of the newspapers.  Neither petitioners nor Mr. Verb                  
          expressed an opinion as to what the value of the newspapers and             
          comic sections would be if they were not sold to individual                 
          purchasers interested in specific issues or comic strips.                   
               Respondent relied on the valuation determination of Mr.                
          Hughes.  Mr. Hughes’ appraisal was thorough, detailed, provided             
          explanations, and was supported by accompanying exhibits.  His              
          testimony was consistent with the analysis in his appraisal, and            
          he demonstrated considerable knowledge in the area of early and             
          rare newspapers.  Mr. Hughes is a well-known newspaper collector            

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