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the basis of the price listed on the receipt, we find that the
fair market value of this bracelet was $12,400 as of the
applicable valuation date.
The decedent typically purchased diamond bracelets with
one-ct. diamonds set all the way around each bracelet.
Hesselgesser and his wife saw decedent with “several” bracelets,
and Standard saw 8 or 10 diamond tennis bracelets and believed
that at least 1 of those bracelets had an assortment of diamonds
which were 1 carat each. The decedent gave Wong two diamond
tennis bracelets, one with 10.5 carats of diamonds and the other
with approximately seven carats of diamonds. The decedent bought
one of the bracelets given to Wong at a coin show, and he bought
the other bracelet given to Wong from Mamiye. We decide that the
taxable estate included seven unreported diamond tennis bracelets
(average of nine bracelets seen by Standard less the two
bracelets given to Wong), and that one of these seven bracelets
had one-ct. diamonds all around it.
For the diamond tennis bracelet with one-ct. diamonds all
around it, we find that its fair market value was $108,000 as of
the applicable valuation date. The parties stipulated that the
tie tack with a one-ct. diamond had an applicable fair market
value of $4,500. On the basis of our review of the pictures and
descriptions of the items displayed in the auction catalogue of
Christie’s in evidence (auction catalogue), we decide that this
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