Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 39

          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                  
                         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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