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We find that, as of the applicable valuation date, the fair
market value of each of the six assets which did not sell at
auction equaled its fair market value as ascertained by Carmona.
In other words, we find that the fair market values of the five
items of jewelry which did not sell at auction totaled $37,200
and that the fair market value of the single gemstone that did
not sell at auction was $9,100. We find that the individual
values of these six assets are as follows:
Jewelry
Lady’s 18-kt. yellow gold, sapphire, and
diamond necklace $4,400
Lady’s 18-kt. yellow gold, ruby, and
diamond necklace 5,800
Cultured pearl necklace with 14-kt. white
gold clasp 400
Lady’s 18-kt. yellow gold, emerald, and
diamond necklace 19,000
Lady’s 18-kt. yellow and white gold, opal,
and diamond pin/pendant combination with
treated opal necklace 7,600
37,200
Gemstone
One loose cushion-shape-natural 18.2-ct. sapphire 9,100
46,300
We consider Carmona to be most helpful to our valuation of
each of these six assets. Carmona testified as to jewelry in
general that the typical buyer of jewelry at auction is a dealer
and that jewelry usually passes from a 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. As to the six items of jewelry
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