- 20 - was no more or less than the $612,000 fair market value of the incomplete residence. Accordingly, we hold that the fair market value of the residence at decedent’s death was $612,000, as reported by the estate. We also hold that the estate is not entitled to deduct the possibility of future obligations to Krueger or required to include the possibility of reimbursements from Chubb. The effect of our holdings is a net increase of $122,400 to the gross estate. The last issue we must consider is whether the estate failed to include in the gross estate the amount of $88,506 that respondent concluded was equal to the value of reimbursement for household furnishings lost in the fire. Respondent reaches the conclusion that the estate failed to report the value of household furnishings. The record shows that Chubb paid decedent $573,761.59 prior to her death, and that amount, according to the terms of the policy, was, in part, for the contents lost in the fire. Respondent became aware of an $88,506 amount subsequently received by the estate as part of a larger insurance reimbursement payment. The $88,506 amount had been labeled and characterized by Chubb as for “contents”. Respondent has concluded that Chubb’s labeling part of the payment as “contents”Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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