Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 12

               Respondent retained an expert, Charles I. Carmona (Carmona),           
          Graduate Gemologist in Residence, Accredited Senior Appraiser,              
          who, on direct examination, testified through his written report,           
          see Rule 143(f)(1), that he had ascertained the applicable fair             
          market values of 25 of the seized assets (25 seized assets) and             
          that those values were as stated in that report.  (We attach                
          hereto as appendix A Carmona’s description of each of the 25                
          seized assets, its appraised value, and, in the case of 19 of the           
          assets sold by Christie’s at auction, its auction price.)  We               
          considered Carmona to be helpful to our valuations of some of the           
          disputed assets, and we relied on his opinion, which was credible           
          and without contradiction.                                                  
               Carmona examined and researched each of the 25 seized assets           
          and opined that the fair market value of those assets for Federal           
          estate tax purposes was the “average price that each item in its            
          current (used) condition might resell to the public in its most             
          common retail outlets in the Estate’s local area”.7  He opined              
          that the proper resale prices for jewelry were the prices                   
          obtained at a retail jewelry store and that the proper resale               
          prices for loose gemstones were their wholesale prices increased            

               7 Carmona noted in his report that “the [25] items listed              
          have been examined and researched to the best of my ability, but            
          not under ideal conditions (cramped quarters, time constraints,             
          artificial light).”  When Carmona examined the 11 items of                  
          jewelry included within the 25 seized assets, he observed that              
          most of those items still had tags on them and that none of the             
          items showed any signs of wear.                                             

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