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value was unreported by the coexecutors primarily for the Isfahan
rug, but for other rugs as well.
g. Jade collection
The Schiffer document lists the value of the decedent’s jade
collection at $250,000 as of February 21, 1992. Schiffer
obtained this value from the decedent. The decedent purchased
$45,000 of jade from Lloyds on December 5, 1988. The decedent
purchased other items of jade at other times.
The coexecutors reported on the estate’s Federal estate tax
return that the only jade included in the taxable estate was two
jade plaques with a fair market value of $2,500. The reported
value equaled the amount on the Butterfield appraisal shown for
those items. Taking into account the decedent’s own valuation of
his jade collection and allowing the estate credit for the
reported value of the plaques, we find the fair market value of
the remainder of the jade collection at $247,500 as of the
applicable valuation date ($250,000 - $2,500).
h. Ivory collection
On May 4 and December 5, 1988, the decedent purchased from
Lloyds numerous items of ivory. The decedent purchased other
items of ivory at other times. On December 7, 1992, the estate’s
accountants prepared a preliminary summary of the estate which
listed the value of the decedent’s ivory collection at $1.5
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