I have a question for Diane Brenner about her appraisal example. (And I'm not arguing; just wondering about this specific experience and trying to integrate it into my understanding of appraisals.) Wasn't the purpose of the appraisal to substantiate the donor's charitable tax deduction? If so, does the I.R.S. acept this sort of business investment value? I ask because we occasionally acquire similar collections, but appraisers generally assess at "fair market value" (which I interpret as "collectors' market"); business investment value would be a totally different concept, and I'm not sure how this would be applicable to a museum collection unless the museum wanted to use the material the same way a commercial business would (leaving aside the whole question of whether a museum could or should do so). I hope some legal eagles out there can address this issue. Having asked those questions, I'd like to return to "fair market value" and offer a caveat about an inconsistency I've detected in the practices of appraisers. I assume that the photographic collections we're discussing contain negatives, which represent relatively uncharted territory. One of the remaining collecting frontiers in photography involves negatives, which seldom have much collector interest, and therefore little "market value." Even negatives by famous photographers whose prints sell in quintuple digits seem to have little collector interest and therefore no established market value. (I predict that this will change eventually.) The appraisers whom I know tend to substitute "value of materials" for items with minimal collector value, but I find this problematic. It seems to me that materials with NO "market value" should be appraised at ZERO. "Value of materials" does not fit the definition of "fair market value." The inconsistency seems to exist because you can't expect a donor to pay an appraiser to say the donation has no value! "Historic value," of course, is not the same thing as "fair market value" either. The difficulty with a large negative collection is that even minimal numbers add up. Is it right for the donor of a collection of 100,000 commercial negatives appraised at $1 each for "value of materials" to take a $100,000 tax deduction for stuff that NO ONE ANYWHERE would buy for $100,000? I don't think so. And of course, if a donor believes such an appraisal and insists on selling it at that price, much frustration can ensue. Appraising is not an exact science, but I'd like to see these issues explored a bit. By the way, I assure you I'm not an IRS agent. --David Haberstich