-59-
($105,000 x .016)) and, indeed, most likely more than that
amount.39 On the basis of the record, we find the fair market
value of the 4.39-ct. diamond at its minimum value of $106,680.
ii. Emeralds
The coexecutors did not include any loose emeralds in the
taxable estate. When he died, the decedent owned numerous loose
emeralds including at least one that weighed eight carats. With
the exception of the eight-ct. emerald, the record does not
establish the carat weight or specifics of any of the other loose
emeralds owned by the decedent.
Respondent did not seize any loose emeralds from the safe
deposit box, but he did seize two 18-kt. gold, emerald, and
diamond necklaces. One of those necklaces, item 2j in the
appendices, had a 6.07-ct. emerald and 270 small diamonds with a
total weight of 10.44 carats. We find supra p. 18 that the
applicable fair market value of this necklace was $19,000. The
other seized necklace, item 2i in the appendices, had a 6.48-ct.
emerald and 245 small diamonds with a total weight of 32.5
carats. The parties stipulated that the applicable fair market
value of this necklace was $19,000.
39 As noted above, we do not consider the auction prices of
Christie’s to be a good gauge of the fair market value of the
related items; we generally view those prices as significantly
less than fair market value.
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