-42- $17,662, $17,662, $8,831, and $4,415, respectively. We decide that, as of the applicable valuation date, a date that is approximately 5 years after this furniture was purchased, the fair market value of each of these categories is 50 percent of the amount which we apportion to it, or, in other words, $17,662, $8,831, $8,831, $4,416, and $2,208, respectively.24 We decide that the sofa table taken by Polachek is the sofa table in category 4. We decide that the applicable fair market value of each of the Baker’s tables is 1/2 of the fair market value of the sofa table, i.e., $2,208 ($4,416/2), and that the fair market values of the three Baker’s tables on the applicable valuation date totaled $6,624 ($2,208 x 3). We are mindful that the estate’s Federal estate tax return contains an “appraisal” opining that the decedent’s home was filled mainly with minimal value assets. That document was prepared by Butterfield & Butterfield (Butterfield) on or about May 13, 1993, and purports to list the fair market values as of 24 We believe that a 50-percent reduction of the apportioned amounts adequately compensates for the fact that the decedent purchased this furniture approximately 5 years before the applicable valuation date and that furniture in general tends to decrease in value over time. Judging by the prices which the decedent paid for this furniture, we conclude that it was furniture of the highest quality. We also note that the decedent purchased this furniture in “Bulk” at a “special” price that apparently was less than the total retail price of that furniture if each piece of it had been purchased separately. The decedent also was an elderly man who tended to live either alone or with one other person, a factor which we believe would conserve the condition of the furniture.Page: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
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