-54-
million as of March 18, 1992. Gonzalez believed that the ivory
collection was worth an amount consistent with that valuation.
We decide that the decedent had a significant ivory
collection when he died. We find consistent with the preliminary
statement and Gonzalez’s understanding of the decedent’s ivory
holdings that the fair market value of the decedent’s ivory
collection was $1.5 million as of the applicable valuation
date.36
i. Loose Gemstones
i. Diamonds
The Schiffer document lists the value of the decedent’s
diamond collection at $500,000 as of February 21, 1992. Schiffer
obtained this value from the decedent. The decedent estimated
this value conservatively and not as an accurate gauge of the
fair market value of his diamonds. Respondent seized 13 loose
diamonds from the safe deposit box, and those diamonds were
appraised by Carmona at a fair market value of $1.1 million and
sold at auction for a total price (exclusive of buyer’s
commissions) of $764,600. The seized diamonds, their values as
36 As stated supra note 29, we give little weight to a
letter written by Christie’s stating that “most” of the
decedent’s Chinese artifacts were of modern or late production.
In addition to the fact that we do not know whether Christie’s
examined all of the decedent’s ivory collection, or actually
considered ivory to be a Chinese artifact, we note that
Christie’s acknowledged in its letter by its use of the word
“most” that some of the Chinese artifacts which it examined were
not of modern or late production.
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