-66-
applicable valuation date; i.e., the same fair market value that
we find for the ruby necklace listed as item 2e in the
appendices.
k. Necklaces
Respondent seized seven necklaces from the safe deposit box.
The receipts from Lloyds establish that the decedent purchased
six other necklaces which were not seized by respondent. The
May 4, 1988, receipt indicates that the decedent purchased on
that date a diamond necklace, a sapphire necklace, and a ruby
necklace. Testimony establishes that the diamonds on the diamond
necklace were all the same size and were set in yellow gold. The
May 5, 1988, receipt indicates that the decedent purchased on
that date a necklace with a 26.73-ct. diamond. The December 5,
1988, receipt indicates that the decedent purchased on that date
an 11-millimeter-wide, 30-inch-long turquoise necklace and a
necklace with graduated diamonds weighing 30.02 carats.
Testimony establishes that the diamonds on the graduated necklace
sloped down in size to one carat on the front stones and were set
in white gold with yellow gold on the bottom. We find that the
decedent retained ownership of these six unseized necklaces at
his death.
i. Diamond Necklaces of May 4, 1988
As to the three necklaces purchased on May 4, 1988, the
May 4, 1988, receipt shows that the decedent paid a bulk price of
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