-55-
appraised by Carmona, and their auction prices (exclusive of
buyer’s commission) are as follows:
Carat Carmona’s Auction Price
Weight Appraised Value of Christie’s
1.9 $11,800 $9,600
2.01 15,000 7,500
3.35 52,300 25,000
4.03 19,600 7,500
4.32 97,000 105,000
5.01 48,000 35,000
6.62 21,500 20,000
6.65 22,000 24,000
7.57 48,000 30,000
7.74 35,800 27,000
11.13 59,000 44,000
18.28 210,000 210,000
40.02 460,000 220,000
1,100,000 764,600
The decedent also purchased from Lloyds in 1988 seven loose
diamonds which were not reported on the Federal estate tax return
and which were not included in the 25 seized assets. Five of
these diamonds were purchased on January 16, 1988, one was
purchased on May 4, 1988, and one was purchased on December 5,
1988. The five diamonds purchased on January 16, 1988, are an
emerald-cut 2.08-ct. diamond, an emerald-cut 2.28-ct. diamond
with VS1 clarity, a GIA certificate round 3.04-ct. diamond with
VVS2 clarity and I color, a heart-shape-baguette 5-ct. diamond,
and a round-cut 5.22-ct. diamond. The diamond purchased on
May 4, 1988, was a masterpiece 4.39-ct. diamond with a faint blue
color. The diamond purchased on December 5, 1988, was a round
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