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other checks, representing the balance of $701,000, reference no
receipt in the record, nor are referenced in those receipts.
c. Receipts From Mamiye to the Decedent
Two receipts which Mamiye gave to the decedent reflect the
decedent’s purchase from Mamiye of $485,000 of diamonds in 1989.
The first receipt reflects the decedent’s February 16, 1989,
purchase from Mamiye of a round 6.62-ct. diamond with VS1
clarity, a round 6.65-ct. diamond with VS1 clarity, and a round
7.81-ct. diamond with VS1 clarity. The receipt states that the
decedent purchased these items at the “bulk special” price of
$125,000. The receipt states that the decedent was required to
pay $50,000 down and $75,000 in 30 days, and that the decedent
had “left as trade 7 ct. 74 pt. Round until sold, and to be set’
for sale and ownership to Ed’”.
The second receipt reflects the decedent’s May 5, 1989,
purchase from Mamiye of a yellow 5.01-ct. diamond, an 8.53-ct.
diamond, and an 11.13-ct. diamond. This receipt states that the
decedent purchased these items in a “Bulk Lot” for a “Special”
price of $175,000 and that the price for the diamonds, if
purchased separately, would have been $75,000, $85,000, and
$200,000, respectively.
In 1989, the decedent made a $100,000 pledge to a charity.
In connection therewith, the decedent donated the 7.81 and
8.53-ct. diamonds to the charity during 1990 and 1991. The other
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