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was no more or less than the $612,000 fair market value of the
incomplete residence.
Accordingly, we hold that the fair market value of the
residence at decedent’s death was $612,000, as reported by the
estate. We also hold that the estate is not entitled to deduct
the possibility of future obligations to Krueger or required to
include the possibility of reimbursements from Chubb. The effect
of our holdings is a net increase of $122,400 to the gross
estate.
The last issue we must consider is whether the estate failed
to include in the gross estate the amount of $88,506 that
respondent concluded was equal to the value of reimbursement for
household furnishings lost in the fire. Respondent reaches the
conclusion that the estate failed to report the value of
household furnishings. The record shows that Chubb paid decedent
$573,761.59 prior to her death, and that amount, according to the
terms of the policy, was, in part, for the contents lost in the
fire. Respondent became aware of an $88,506 amount subsequently
received by the estate as part of a larger insurance
reimbursement payment. The $88,506 amount had been labeled and
characterized by Chubb as for “contents”. Respondent has
concluded that Chubb’s labeling part of the payment as “contents”
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