Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek - Page 37

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          the applicable value of the decedent's Sterling preferred stock             
          was approximately $2,708,536 ($827,298 + $900,676 + $980,562) on            
          September 18, 1992.                                                         
               We need not pinpoint exactly the fair market value of the              
          decedent's Sterling preferred stock on the applicable valuation             
          date.  Suffice it to say that respondent determined that the                
          applicable value of the decedent's Sterling preferred stock                 
          (including the accrued dividends) was $1,947,845, a value which             
          is approximately 28 percent less than the approximate fair market           
          value which we determine herein, and the estate has not persuaded           
          us that the actual fair market value was less than respondent's             
          determination.  We sustain respondent's determination on this               
          issue.  See Anselmo v. Commissioner, 80 T.C. 872, 886 (1983),               
          affd. 757 F.2d 1208 (11th Cir. 1985).                                       
          2.  Two Hundred Twenty-Seven Gold Coins                                     
               a.  The 191 Coins                                                      
               Respondent determined that the applicable value of the                 
          191 coins was $8.5 million.  Respondent called an expert,                   
          Steven Conturi (Mr. Conturi), to support this determination, and            
          the Court received his report into evidence.  See Rule 143(f).              
          Mr. Conturi has been in the retail and/or wholesale rare coin               
          business since 1975.  He ascertained that the value of the 191              
          coins was $9,081,000, by referencing the price at which the coins           
          last traded on the open market as listed in certain numismatics             





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