-61-
iii. Opals
The coexecutors did not include any loose opals in the
taxable estate. Testimony establishes that the decedent owned
“numerous” opals when he died. Whereas the record does not
establish the number or specifics of any of these “numerous”
opals, we decide conservatively that the decedent owned two opals
when he died.
We believe that it is reasonable on the basis of the facts
and circumstances at hand to conclude that the fair market value
of each of the decedent’s two opals was the same as the fair
market value of each of the decedent’s emeralds. We find that
the fair market value of the opals totaled $32,300 (2 x $16,150).
iv. Ruby
Lloyds’s receipt number 597, dated May 5, 1988, reported
that the decedent purchased an 18-ct. ruby from Lloyds for the
price of $7,500. We find that the decedent retained ownership of
this ruby at his death. On the basis of the price listed on the
receipt, we find that the fair market value of the 18-ct. ruby
was $7,500 as of the applicable valuation date.
v. Sapphires
The coexecutors did not include any loose sapphires in the
taxable estate. Respondent seized from the safe deposit box one
loose blue sapphire, 18.2 carats in size, which we valued supra
p. 18 at $9,100. That sapphire was not the same sapphire as
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