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We decide that the fair market values of the two emerald
necklaces is most probative of the fair market value of the
eight-ct. emerald. On the basis of the $19,000 value, we find as
of the applicable valuation date that the fair market value of
the eight-ct. emerald was $16,150. We find the $16,150 fair
market value by increasing the $19,000 by 27.5 percent ($19,000 x
.275 = $5,225) to reflect the fact that the eight-ct. emerald is
27.5 percent larger than 6.275 ((8 - 6.275)/6.275 = .275), which
is the average weight of the emeralds on the necklaces in items
2i and 2j, and then decreasing the total of $24,225 ($19,000 +
$5,225) by one-third ($24,225/3 = $8,075) to account for the fact
that the $24,445 value included a necklace that was 18-kt. gold
and had an assortment of small diamonds ($24,225 - $8,075 =
$16,150).
We find a fair market value of $32,300 for other emeralds
owned by the decedent when he died. Although the record does not
establish the exact number of other loose emeralds owned by the
decedent when he died, we surmise from the record that the
decedent must have then owned at least two other loose emeralds.
We decide conservatively that the decedent owned two other
emeralds when he died, that the value of each of those emeralds
was the same as the eight-ct. emerald, and that the total fair
market value of those two other emeralds was two times the fair
market value of the eight-ct. emerald ($16,150 x 2 = $32,300).
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