Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 46

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          appraised them on the spot.  We also know that Gonzalez testified           
          that she took three of the decedent’s rugs to her home in                   
          Florida, that she later had those rugs appraised in Florida by              
          what she described as a “legitimate company”, and that the                  
          company appraised the rugs at $4,000.  Gonzalez effectively                 
          conceded at trial that Butterfield did not recognize the value of           
          those rugs and did not meaningfully appraise them.29                        
                         c.  Thousand dollar watch                                    
               Schiffer testified that the decedent wore a “thousand                  
          dollar” watch.  The coexecutors did not report any watch on the             
          estate’s Federal estate tax return.  On the basis of Schiffer’s             
          testimony, we find that the fair market value of the decedent’s             
          “thousand dollar” watch was $1,000 as of the applicable valuation           
          date.                                                                       
                         d.  Cash at home                                             
               The coexecutors reported on the estate’s Federal estate tax            
          return that all of his money (exclusive of coin collections) as             
          of the applicable valuation date was held in financial                      
          institutions.30  The coexecutors did not report any cash that the           

               29 For similar reasons, we also give little weight to the              
          fact that Christie’s wrote a letter to Gonzalez stating that it             
          was unable to prepare an insurance appraisal of some of the                 
          Chinese artifacts in the decedent’s home because “Most of these             
          items are of modern or late production.  * * *  I would suggest             
          that you either call in a local appraiser or insure at the cost             
          prices.”                                                                    
               30 The coexecutors reported that the decedent had at                   
          financial institutions two money market accounts and two checking           
                                                             (continued...)           



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