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either the Ceylon genuine masterpiece 18.02-ct. sapphire shown on
the pertinent Lloyds’s receipt of December 5, 1988, or the 18-ct.
sapphire shown on the Lloyds’s receipt of May 5, 1988. We find
that the decedent retained ownership of the 18-ct. sapphire and
the 18.02-ct. sapphire at his death.
We find that the fair market value of the 18-ct. sapphire
was $6,000 as of the applicable valuation date. Lloyds listed
that amount on the May 5, 1988, receipt as the price of that
sapphire. On the basis of our valuation of the seized 18.2-ct.
sapphire and the fact that the 18.2-ct. sapphire was for
practical purposes the same weight as the 18.02-ct. sapphire, we
find that the fair market value of the 18.02 sapphire was $9,100
as of the applicable valuation date. We attribute the
differential between the valuations of $6,000 for the 18-ct.
sapphire and $9,100 for each of the 18-ct. and 18.02 ct.
sapphires to the fact that the two more expensive sapphires were
a “blue” sapphire and a “genuine masterpiece” “Ceylon” sapphire,
respectively.
j. Bracelets
i. Diamond
On January 16, 1988, the decedent purchased from Lloyds an
18-kt. gold bracelet with a 9.5-ct. diamond. The receipt for
that item reported that its price was $12,400. We find that the
decedent retained ownership of this bracelet at his death. On
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