Just playing devil's advocate here, if you're using the price with a buyer's premium as a jumping off point, a PSA 10 Diamond Anniversary sold for $3,700. A PSA 10 BC Auto went for $16,800. Is it just a coincidence that the Heritage sales went for all-time highs compared to their eBay counterparts? If you compare Heritage Auctions sales to eBay sales, it's pretty clear that Heritage is causing cards to sell for more than they typically would.
Just a different perspective but I think it's more nuanced than buyer's premium + hammer price = FMV.
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