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of what it had cost. Khalaf did not opine as to the general
value of such jewelry in 1992.
We note that at trial neither party provided timely
independent expert witnesses as to the value of the jewelry
transferred to Khalaf. Even if experts had been called, due to
Al Zuni’s and Khalaf’s failure to have available a written
inventory, books and records, or other documentation describing
the specific items of jewelry transferred to Khalaf, such experts
would not have had sufficient information to make professional
valuations of the jewelry inventory transferred to Khalaf, and
their testimony would not have been helpful.
On the limited evidence before us (including petitioners'
and American Silver's written contemporaneous representations as
to the value of the jewelry, the evidence reflected on Al Zuni's
tax returns as to the cost of the jewelry inventory that Khalaf
purchased for Al Zuni in 1990, 1991, and 1992 in the $1 million
plus range and regarding the cost of the jewelry inventory Al
Zuni had on hand at yearend 1990 and 1991 in the one-half million
dollar range), we conclude that the value of the jewelry
inventory transferred to Khalaf on September 15, 1992, was
$671,413.
With regard to Al Zuni’s cost basis in the jewelry inventory
transferred to Khalaf on September 15, 1992, the parties
stipulated that the jewelry inventory had a cost basis to Al Zuni
of $538,000. Subtracting the $538,000 cost from the $671,413
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