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than $15,335, and that at least one recent appraisal had listed
the value of his stock in excess of $3 million. Ms. Bates had
also valued the decedent's stock 1 month earlier at $462,000, a
value which included a 70-percent discount that she believed
applied primarily to take into account the decedent's minority
interest and the fact that the stock was not paying dividends.
Ms. Bates brought her $462,000 valuation to the attention of
Ms. Gonzalez in or about April 1993. Ms. Bates reported the
value of the decedent's 191 coins at $3,192,175 based on Mr.
Leidman's corresponding appraisal. Ms. Gonzalez did not inform
Ms. Bates that Mr. Leidman had valued these coins at $8.5 million
on another occasion. Ms. Bates asked Ms. Gonzalez whether the
decedent owned any jewelry or diamonds at the time of his death.
Ms. Gonzalez answered "no", and Ms. Bates did not report any
jewelry or diamonds as assets of the decedent's estate.
On or before June 10, 1993, Frankel Lodgen presented
Ms. Gonzalez with the decedent's estate tax return. She reviewed
this return at length with Ms. Bates, and both Ms. Bates and
Ms. Gonzalez signed the return on that day. Ms. Polachek signed
the return 1 day later, and 5 days after that, the coexecutors
filed the decedent's estate tax return with respondent. The
coexecutors, on behalf of the estate, elected to value the estate
on the alternate valuation date of September 18, 1992. The gross
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