Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 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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