Estate of Mary B. Bull - Page 20




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          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”           










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