-40-
Avenue location of Lloyds, and that he obviously paid a
significant amount of money to ship that furniture cross-country
to his home in California.
We find as of the applicable valuation date that the fair
market values of the sofa table and each of the three Baker’s
tables were $4,416 and $2,208, respectively.19 Lloyds gave to
the decedent three sequentially numbered receipts for his
purchases of January 16, 1988, totaling $650,000. Receipt number
564, the last of these three receipts, listed nine pieces of
furniture purchased by the decedent. Neither party has suggested
that this sale was not a valid, arm’s-length sale, and we
consider it as such.20 The parties stipulated that item numbers
1, 3, 4, 5, and 8 on receipt number 562 and the only two items on
receipt number 563 had as of the applicable valuation date a
total fair market value of $320,600.21 As discussed infra pp.
56-58, 62-63, we find that the fair market values of the
remaining items on receipt number 562 totaled $245,506 as of the
19 We understand the sofa table to be much larger than each
of the Baker’s tables, which we understand are the same size.
Although Polachek suggested that the sofa table had a broken leg
that made it worthless, we find this suggestion incredible.
20 The decedent also must have considered this sale to have
been on good terms as he proceeded afterwards to frequent Lloyds
continually and to spend large sums of money there.
21 Those items correspond respectively to item numbers 19,
5, 6, 9, 10, 8, and 7 on our list of assets stipulated as to
existence and fair market value.
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