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the estate tax return as the stock's value. Ms. Gonzalez also
knew that Ms. Bates had valued the stock at $462,000 1 month
before she valued it at $15,335. Given Ms. Gonzalez's education
and business acumen, as well as her knowledge that the preferred
stock was entitled to certain preferences, that the preferred
stock was accruing dividends daily at a substantial rate, that
the preferred stock was soon going to be subject to a mandatory
redemption, and that a redemption of the preferred stock would
result in the holder(s) thereof receiving millions of dollars in
proceeds, we are hard pressed to conclude, as requested by the
estate, that Ms. Gonzalez was ignorant of the approximate value
of the decedent's Sterling preferred stock, or that she thought
that the stock was worth only $15,335. We conclude the contrary.
Second, the estate undervalued decedent's gold coins by a
significant amount. The estate reported that the applicable
value of the 191 coins was $3,192,175, and that the applicable
value of the additional coins was $275,400. We have determined
that the applicable values were $7,635,000 and $494,523,
respectively. The total value that we have determined for the
coins is $4,661,948 more than the total value reported by the
estate, or, in other words, the reported total value was
approximately 42.7 percent of the determined total value.
Ms. Gonzalez knew that the 191 coins had been appraised at a
significantly higher amount than the value reported on the
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