-9-
Hodgdon v. Commissioner, 11 T.C.M. (CCH) 898, 1952 T.C.M. (P-H)
par. 52,259 (1952), and that those assets, not having been shown
to have been relinquished by the decedent, were includable in the
taxable estate, see, e.g., Estate of Bograd v. Commissioner, T.C.
Memo. 1988-34, affd. 887 F.2d 1084 (5th Cir. 1989). We also
infer from this evidence that the taxable estate includes other
assets which were not listed in the receipts but which the
decedent possessed and controlled near the time of his death and
were not shown by the estate to have been relinquished by him.
As we stated in Trompeter I, the assets in this third category
“consist mainly of gems, jewelry, furniture, and a music
collection.” Estate of Trompeter v. Commissioner, T.C. Memo.
1998-35. As detailed below, these assets also include cash at
home, 31 coins, rugs, jade, and ivory.
We set forth below by these three categories the assets
which we find were omitted from the taxable estate and the fair
market values which we find as of the applicable valuation date.6
These fair market values represent our findings as to “the price
6 The coexecutors elected to have the estate valued as of
the alternate valuation date of sec. 2032(a). Thus, the
applicable valuation date is generally Sept. 18, 1992. See
generally sec. 20.2031-1(b), Estate Tax Regs. (“The value of
every item of property includible in a decedent’s gross estate
under sections 2031 through 2044 is its fair market value at the
time of the decedent’s death, except that if the executor elects
the alternate valuation method under section 2032, it is the fair
market value thereof at the date, and with the adjustments,
prescribed in that section.”).
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