-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 NextLast modified: May 25, 2011