-67-
$235,000 for 26 items. Included in those items are ivory, a
diamond necklace, a sapphire necklace, a ruby necklace, a ruby
ring, a sapphire ring, and a faint blue masterpiece 4.39-ct.
diamond. We apportion the $235,000 sales price among these
categories in the following manner.
First, we apportion $75,000 to the ivory. Exclusive of the
ivory, the May 4, 1988, receipt lists six items. We conclude
that the remaining 20 items referenced in the receipt were pieces
of ivory that are included within the ivory shown on the receipt
in the categories “erotic giga”, “Wise mens”, “Erotic”, or “40
tall 3 figure”. On the basis of our decision supra pp. 51-52
that $3,750 was a reasonable amount to attribute to each piece of
ivory, we conclude that the fair market value of the ivory
referenced in this receipt totals $75,000 (20 x $3,750). Second,
we apportion $106,680 to the 4.39-ct. diamond to reflect our
valuation of that diamond supra pp. 58-59. Third, we decide that
the balance of $53,320 ($235,000 - ($75,000 + $106,680)) was
attributable to the remaining three necklaces and two rings. We
apportion the $53,320 to those items using a weighing process
under which we decide (following, in part, our examination and
comparison of the appraised values of the necklaces and rings
shown in appendix A) that each of the necklaces was worth the
same amount and that each of the rings was worth 1/2 of the value
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