-11-
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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