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as shown on the decedent's estate tax return. Respondent further
contends that, because petitioner was the executrix of the
decedent's estate and signed the estate tax return that listed
the value of the total gross estate as $544,856, petitioner is
estopped from asserting a different estate value.
Petitioner asserts that the transfer was for a reasonably
equivalent value because the items transferred to her from the
decedent consisted of liabilities in excess of assets.
Petitioner testified that the values on the estate tax return
were incorrect, the items were subject to encumbrances, and the
values were artificially inflated so that she could receive a
higher step-up in basis. The values submitted by petitioner on
the estate tax return are an admission by petitioner, and lower
values cannot be substituted without cogent proof that the
reported values were erroneous. Estate of Hall v. Commissioner,
92 T.C. 312, 337-338 (1989). The Sacramento County tax
assessment offered by petitioner is insufficient to establish the
fair market value of residential property because there is no
evidence of the manner in which the assessed value was
determined. Residential property assessments in California are
limited by law and not necessarily based on fair market value.
Cal. Const. Code art. 13A, sec. 2(a) (West 1996). Likewise,
petitioner's unsupported testimony as to the value of other items
is speculative and insufficient. Petitioner has failed to
produce any evidence that would overcome the admission and
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