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This amount is computed as the lesser of (a) and (b) above multiplied by the proportion of the fair market value of the gifted property is of the fair market value of the capital property, as follows: $2,000 x $500/$2,500 = $400 Further, for the purposes of determining the proceeds of disposition of the substantive gift, the sale price of the substantive gift ($2,500) is reduced by the difference between the fair market value of the gifted property ($500) and its deemed fair market value ($400). ...

In applying this factor, external influences such as economic conditions may affect the sale of artistic or literary works, will be taken into consideration. 1.25 No particular factor described in ¶1.24 is more important than another …. 1.26 In the case of an artist or writer, it is possible they may not realize a profit during their lifetime. ...