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decedent as of that date and each asset’s estimated fair market
value. Schiffer generally obtained these estimates by asking the
decedent his opinion as to each asset’s value. Beforehand,
Schiffer had advised the decedent that he should be conservative
in estimating value for this purpose because the higher the
value, the greater the estate tax. The document listed that the
decedent’s music collection had an estimated fair market value of
$50,000 as of February 21, 1992.
Gonzalez took the decedent’s music collection to her home in
Florida after he died, and the coexecutors did not report any
value for this collection on the Federal estate tax return. We
find on the basis of Schiffer’s document and testimony that the
fair market value of this collection was $50,000 as of the
applicable valuation date. We are mindful that the fair market
value of this collection could be significantly higher than
$50,000 given the voluminous size of the collection, the
decedent’s earnest desire to have the finest collection of
reel-to-reel tapes which money could buy, the decedent’s
financial ability to fulfill that desire, and Schiffer’s advice
to the decedent to estimate the value of the listed assets
conservatively.
b. Baker’s tables/sofa table
By her own admission, Polachek removed three Baker’s tables
and a long sofa table from the decedent’s home after he died.
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