Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 43

                                        -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.                                                 





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