Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 41

          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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