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or Mr. Blodgett’s expertise in art, the obtaining of a market
analysis on the painting, or a history of investments in art.
Mr. Blodgett’s expectation of 500 percent or more appreciation in
the value of the painting can best be described as a speculative
hope. Moreover, the element of personal pleasure from owning the
painting was evident from Mr. Blodgett’s description of buying it
for his wife. The Court holds that personal pleasure was the
primary reason for having the painting. Its loss was a
nondeductible personal, living, or family expense. Sec. 262.
Respondent is sustained on this issue.
Finally, petitioner claimed carryforward business or
investment losses of $561,375 on rare coins and $125,403 on
historical documents. She characterized the losses on the coins
as rare coins held personally, $302,500; rare coins mishandled
out of Safrabank personal loan account in 1991, $155,650; and
rare miscellaneous coins lost in 1994 to 1997, $103,225.
Petitioner presented scant evidence regarding the historical
documents. Petitioner did not meet her burden of proof with
respect to the ownership, the value, and the transfer of the
coins and rare documents. The Court disregards petitioner’s
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