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consisted of the 8 coins which went unsold at the February 1992
auction and two other coins for which the record does not
disclose the history. The 36 additional coins were described on
the estate tax return as "Additional group of gold coins" and
35 of these coins were valued on the return at $275,400. No
value was placed on the 36th coin.
In February 1992, the decedent instructed his personal
accountant, Henry Schiffer (Mr. Schiffer), to prepare a list of
the decedent's assets and each asset's estimated value. The
document was entitled "Ed Trompeter asset list (not including
coins) as of February 21, 1992". The document was based on
conversations between Mr. Schiffer and the decedent, records
maintained in Mr. Schiffer's office, and his contacts with people
who maintained other records for the decedent. Included on Mr.
Schiffer's one-page list was, among other things, a gun
collection valued at $10,000, a music collection valued at
$50,000, and diamonds and other gems totaling $500,000. None of
these items were included on the decedent's estate tax return.
IV. Pertinent Claims Against the Estate
The decedent and Ms. Trompeter separated on August 8, 1984,
and 2 years later they were in the midst of a divorce proceeding.
During the pendency of this proceeding, Barry Stuppler (Mr.
Stuppler), president of a coin and appraisal store named Gold
& Silver Emporium, prepared two disclosure statements identifying
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