-41-
applicable valuation date.22 When we take into account credible
testimony in the record to the effect that the value of jewelry
and gemstones has remained virtually the same throughout the
relevant time period, we conclude that the balance of the
$650,000 sales price, i.e, $83,894 ($650,000 - ($320,600 +
$245,506)), must be attributable to the nine items of furniture
on receipt number 564.
The nine items of furniture basically consist of: (1) A
mother-of-pearl inlay dining room set with a carved pedestal and
14 chairs, (2) two curio cabinets with mother-of-pearl inlay,
(3) a black artwork lacquer desk and matching chair, (4) a sofa
table with 48-inch beveled glass, and (5) a black Ming chair. On
the basis of our perception of the value of the items in these
five categories, we assign the following weights to these
categories to apportion the $83,894 amongst them: 8, 4, 4, 2,
and 1, respectively.23 In that the sum of these weights totals
19 (8 + 4 + 4 + 2 + 1 = 19), we apportion 8/19, 4/19, 4/19, 2/19,
and 1/19 of the $83,894 to the respective categories. Our
apportionment of the $83,894 to the five categories is $35,324,
22 We find that the fair market values of the two diamonds
in item number 2 were $75,000 and $78,150 and that the fair
market values of the items in item numbers 6, 7, 9, and 10 were
$47,436, $12,400, $15,510, and $17,010, respectively.
23 In other words, we decide that the item in category 1 was
worth twice as much as each of the items in category 2 and 3,
four times as much as the item in category 4, and eight times as
much as the item in category 5.
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