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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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