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2. Specific Assets
a. Music collection
When he died, the decedent owned a music collection
consisting of reel-to-reel tapes (and to a lesser extent records)
and three or four tape players. The decedent had been collecting
reel-to-reel tapes for approximately three decades, and his
life’s goal was to own the best collection of reel-to-reel tapes
which money could buy. The decedent’s music collection was
unique and of fine quality, consisting mainly of music from the
1920s and 1930s and including tapes of the famous Italian tenor
Caruso and numerous other tapes of music from Latin America
through music of the present day. The decedent kept his tapes at
home in several rooms. In one room, in particular, the room
where he routinely listened to his tapes on a high quality,
highly sensitive sound system, the decedent covered one wall
completely with his tapes.
Henry Schiffer (Schiffer) was the decedent’s accountant and
a long-time friend. Once or twice a month, Schiffer would visit
the decedent at his home to handle his accounting requirements or
simply to converse with him in his music room or in his gazebo.
For estate tax purposes, Schiffer prepared a one-page document
entitled “ED TROMPETER ASSET LIST (NOT INCLUDING COINS) AS OF
FEBRUARY 21, 1992". This document listed Schiffer’s
understanding of some (but not all) of the assets owned by the
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