-52-
ivory was $2,500 per item ($2,000 + ($2,000 x .25)), and that the
retail sales price for ivory was $3,750 per item ($2,500 +
($2,500 x .50)).
Third, we apportion $25,000 to the item of netsukes to
reflect the fact that the decedent had on May 4, 1989, paid that
amount for other netsukes. Fourth, we apportion $4,416 to the
two rosewood tables to reflect our finding supra p. 42 that the
Baker’s tables were each worth $2,208 and our decision that the
Baker’s tables are a good measure of the value of the rosewood
tables. Fifth, we apportion $66,404 to the diamond necklace,
$9,000 to the diamond earrings, $35,800 to the 7.75-ct. diamond,
and $9,100 to the 18.02-ct. sapphire to reflect our findings
infra pp. 58, 62, 69-70, 73, of those fair market values. Sixth,
we apportion the remaining $62,530 of the $276,000 sales price to
the 10 rugs.35 We allow the estate credit for $3,000 of rugs
reported on its estate tax return and conclude that $59,530 of
35 To summarize:
Three pieces of jade $45,000
Five pieces of ivory 18,750
Netsukes 25,000
Rosewood tables 4,416
Diamond necklace 66,404
Diamond earrings 9,000
Loose diamond 35,800
Loose sapphire 9,100
10 rugs 62,530
276,000
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