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above, and the 36 coins were sufficiently similar to the 191
coins to allow us to rely on the decedent's valuation of the 191
coins for purposes of valuing the 36 additional coins. The
decedent valued the 191 coins at $7,635,000, a figure that is
18.9 percent lower than the $9,081,000 value ascertained by
Mr. Conturi. Based on our analysis of the 191 coins, we find
that Mr. Conturi overvalued the 36 coins by 18.9 percent. We
conclude that the fair market value of the 36 additional coins on
the applicable valuation date was $494,523 (i.e., $609,770 less
18.9 percent).
3. Fair Market Value of Unreported Items
Respondent determined that the estate failed to report
$14 million in diamonds, jewelry, gems, art, and artifacts.
Respondent's determination is based primarily on Joe Pasko's
(Mr. Pasko) claim for the $1.4 million commission, wherein he
stated that the decedent retained him to sell assets that were
worth at least $14 million. Respondent's determination is also
based on the value of the assets that were seized from the safe
deposit boxes.
The estate has conceded that the estate failed to report
approximately $1 million of this $14 million amount. The estate
argues that certain of the seized assets were property that the
decedent had given in September 1991 to the coexecutors, in their
individual capacities. The estate points to the testimony of the
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