-48-
Stamp & Coin (Superior) before the auction of February 25, 1992.
Given the fact that Gonzalez was well informed as to the extent
of the decedent’s holdings, we conclude that the decedent near
the time of his death owned 500 coins. Of these coins, 201
(209-8) were sold in the auction and 227 (191 + 36) were reported
on the estate’s Federal estate tax return.31 This leaves 72
coins (500 - (201 + 227)), 41 of which were seized and 31 of
which have not been recovered by respondent. In light of the
tough and thorough litigation with Superior, we believe that
those of the 500 coins in Superior’s possession which were not
sold were returned to the decedent.
We find a fair market value of $425,847 for the 31 coins
which were not recovered by respondent. The 201 coins, which
consisted primarily of $1, $2-1/2, and $3 gold coins and certain
pattern gold coins, sold at the first auction for the total
amount of $3,850,622 (an average of $19,157 per coin). The 191
coins, which consisted of $5, $10, and $20 gold pieces and the
Amazonian set, were valued by the Court at $7,635,000 (an average
of $39,974 per coin) as of the applicable valuation date. The 36
31 The decedent consigned to Superior 209 gold proof coins
for auction on Feb. 25, 1992. Of those coins, 201 were sold and
eight were not. The coins reported on the return were those
coins held by Superior when the decedent died. The 191 coins
were at that time consigned to Superior for auction on Oct. 13,
1992. As to the 36 coins, eight of them were the unsold coins
above, and the other 28 were from other consignments made to
Superior before 1991 and for which Superior was awaiting a
written request from the decedent for their return.
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