Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 57

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          7.75-ct. diamond.  We find that the decedent retained ownership             
          of these seven diamonds at his death.                                       
               We find the fair market value of these seven diamonds                  
          through a three-step process.  First, we look to the prices at              
          which Mamiye sold similarly weighted diamonds.37  We consider               
          those arm’s-length retail prices to be the best indicia of fair             
          market value on the basis of the record before us.  If a diamond            
          sold by Mamiye was similar in weight to one of the seven diamonds           
          in question, we use that comparable diamond to measure the fair             
          market value of the diamond in question.                                    
               By its weight, the 5.01-ct. diamond that Mamiye was selling            
          for $75,000, if purchased separately, is comparable to the                  
          five-ct. and 5.22-ct. diamonds in question.  We decide that the             
          five-ct. diamond was for practical purposes the same weight as              
          the 5.01-ct. diamond sold by Mamiye and observe that the 5.22-ct.           
          diamond was 4.2 percent larger in weight than the 5.01-ct.                  
          diamond ((5.22 - 5.01)/5.01 = .042).  We find on the basis of the           
          $75,000 price that the fair market values of the five-ct. and               
          5.22-ct. diamonds were $75,000 and $78,150 ($75,000 + ($75,000 x            
          .042)), respectively, as of the applicable valuation date.                  



               37 We understand that the value of gemstones depends not               
          just on weight but on color, cut, and clarity as well.  The                 
          record before us generally does not allow us to factor color,               
          cut, or clarity into our valuations as to gemstones which are               
          “comparable” to the gemstones in question.                                  





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