-68-
of a necklace.42 As we did similarly above, we assign a weight
of two to each of the three necklaces and a weight of one to each
of the two rings. In that the sum of these weights totals eight
(2 + 2 + 2 + 1 + 1 = 8), we apportion 2/8 of $53,320 to each of
the three necklaces (2/8 x $53,320 = $13,330) and 1/8 of $53,320
to each of the two rings (1/8 x $53,320 = $6,665).43 We find
accordingly that the fair market value of each of the three
necklaces shown on the May 4, 1988, receipt was $13,330 as of the
applicable valuation date.
ii. Diamond Necklaces of May 5, 1988
On May 5, 1988, the decedent purchased from Lloyds an 18-kt.
gold necklace with a 26.73-ct. diamond. The receipt for that
item reported that its price was $74,000. We find that the fair
market value of this necklace was the same as of the applicable
valuation date.
42 The May 4, 1988, receipt states no specific information
on these necklaces and rings, but for the gemstones.
43 To summarize:
Ivory $75,000
4.39-ct. diamond 106,680
Diamond necklace 13,330
Sapphire necklace 13,330
Ruby necklace 13,330
Ruby ring 6,665
Sapphire ring 6,665
235,000
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