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l. Rings
i. Man’s Diamond Pinkie Ring
The decedent wore a “pinkie ring” with a noticeable diamond
in it. We find that the decedent retained ownership of this
pinkie ring at his death. The receipts from Lloyds and Mamiye do
not list any diamond that was purchased by the decedent that was
less than one carat. We decide that the decedent’s pinkie ring
had a diamond weighing at least one carat and value that ring as
if it had a one-ct. diamond in it. Consistent with our valuation
of the one-ct. diamonds in the decedent’s diamond tennis bracelet
that we valued supra pp. 63-64 at $108,000, we decide that the
one-ct. diamond in the pinkie ring had an applicable fair market
value of $4,500. We find that the fair market value of the
decedent’s pinkie ring was $4,500 as of the applicable valuation
date.
ii. Other High Quality Man’s Diamond Ring
The decedent owned a man’s ring with a high quality three-
to four-ct. diamond in it. We find that the decedent retained
ownership of this ring at his death. On the basis of the average
of the range of the size of the diamond (i.e., we view the
diamond as weighing 3.5 carats), and the fact that a 3.5-ct.
diamond weighs 250 percent more than a 1-ct. diamond ((3.5 - 1)/1
= 2.5), we find that the fair market value of the decedent’s
three- to four-ct. diamond ring was 250 percent more than the
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