-69-
iii. Turquoise and Diamond Necklaces of
December 5, 1988
We find that the fair market value of the turquoise necklace
was $21,250 as of the applicable valuation date. Lloyds gave the
turquoise necklace and a wall of ivory art piece to the decedent
in exchange for netsukes. The May 4, 1989, Lloyds’s receipt
reports that the decedent on that date bought from Lloyds other
netsukes worth $25,000,44 and we find supra p. 52 that the
decedent also paid $25,000 for still other netsukes on
December 5, 1988. We decide on the basis of these receipts that
the value of the exchanged netsukes referenced as item one on the
December 5, 1988, receipt also was $25,000. Having decided above
that the value of each ivory item was $3,750, we apportion the
$21,250 difference between $25,000 and $3,750 to the turquoise
necklace.
As to the necklace with graduated diamonds weighing 30.02
carats, we find that the fair market value of this necklace was
$66,404 as of the applicable valuation date. On the basis of our
review of the pictures and descriptions of items displayed in the
auction catalogue, we decide that item numbers 295 and 299 shown
therein were proper measures of the fair market value of the
graduated-diamond necklace in question. Item number 295 was a
16 3/4-inch platinum necklace set with 55 graduated heart-shape
44 Whereas this receipt lists the only purchased item as
“Nestkies”, we understand this description to refer to netsukes.
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