-51-
18).34 Of those 24 items, 10 are rugs, five are pieces of ivory,
three are pieces of jade, one is a 30.02-ct. graduated-diamond
necklace, one is a pair of diamond earrings, one is a 7.75 ct.
diamond, one is a genuine masterpiece 18.02 ct. sapphire, one is
netsukes, and one is two rosewood tables. We apportion the
$276,000 sales price among these items in the following manner.
First, we apportion $45,000 to the three items of jade to
reflect their appraised value. Second, we apportion $18,750 to
the five pieces of ivory to reflect what we decide was a
reasonable $3,750 per piece value for ivory. We ascertain that
per piece value taking into account the fact that Butterfield
appraised two of the decedent’s ivory urns at a per piece value
of $2,000 and that Carmona testified in the setting of jewelry
sales that the fair market value of an item purchased at auction
generally equals the auction price plus a 25 to 50 percent
dealer-to-retailer markup and a 50 to 100+ percent retailer-to-
public markup. On the basis of the record before us, we consider
the sale of jewelry as sufficiently similar to the sale of ivory
for purposes of valuing the latter, and we conservatively apply
the lower range of the estimated markups. In other words, we
find for purposes of our analysis that the retailer’s price for
34 Item 1 in receipt number 565 is the “Turquoise Necklace”
and “Wall of IVORY Art piece”. Whereas receipt 565 states that
this necklace and wall of ivory were given to the decedent in
exchange for netsukes, we do not attribute any of the $276,000 to
those two items.
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