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by the commissions charged by brokers on their sales of gemstones
to the public. He opined that the public usually buys jewelry at
retail from jewelry stores that sell estate jewelry, that the
majority of buyers at public auctions are dealers, that the
lowest level of sales prices for jewelry is found at auction, and
that jewelry usually passes from the dealer to the public through
retail jewelers with a dealer-to-retail-jeweler markup of 25 to
50 percent over cost and a retail-jeweler-to-public markup of 50
to 100+ percent over cost. He opined that the wholesale prices
paid for gemstones by brokers was best ascertained from personal
experience and comparable sales and offers to sell. He opined
that a broker’s commission on a sale of loose gemstones to the
public was typically 15 to 25 percent of the wholesale price.
The assets which we find were omitted from the taxable
estate and the fair market values which we find for these assets
are as follows:8
Assets Stipulated as to Existence
and Fair Market Value
St. Gauden and other bullion coins
seized by respondent from the safe
deposit box $50,000
41 gold coins (different than the
St. Gauden and bullion coins just
listed) seized by respondent from
the safe deposit box 104,500
8 We provide below a brief description of the 25 seized
assets and list in parenthesis at the end of each description the
number and letter that corresponds to Carmona’s specific
description in appendix A.
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