Appraisal of Art and Collectibles

Treas. Reg. § 20.2031-1(b) defines fair market value as the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.

In Anselmo v. Commissioner, the Court quoting Treas. Reg. § 20.2031-1(b) held that the value of gems was the aggregate price that would have been paid for them when purchased in the market in which such stones are "most commonly sold to the public." Id. at 882.

In Goldman v. CIR, 388 F. 2d 476 - Court of Appeals, 6th Circuit 1967, the Court held that the buyer is the ultimate consumer and not what would be paid by a dealer at wholesale. Id. at 478