-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.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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