-56- 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.Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
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