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m. Earrings
Respondent did not seize any earrings from the safe deposit
box. The December 5, 1988, receipt from Lloyds shows that the
decedent had purchased on that day a pair of diamond stud
earrings. We find that the decedent retained ownership of these
earrings at his death.
Consistent with our valuation of the decedent’s pinkie ring,
we decide that each of the earrings had a one-ct. diamond and
that each of these diamonds had an applicable fair market value
of $4,500. We find that the fair market value of the earrings
was $9,000 as of the applicable valuation date.
n. Tie Tack
In addition to the 1-ct. diamond tie tack that was seized by
respondent from the safe deposit box, the decedent owned a tie
tack with a three to four-ct. diamond. We find that the decedent
retained ownership of this tie tack at his death. On the basis
of our finding that the decedent’s man’s ring with a three to
four-ct. diamond had a fair market value of $15,750 as of the
applicable valuation date, we find that this tie tack, which had
a similar size diamond, had a fair market value of $15,750 as of
the applicable valuation date.
o. Pins
The decedent owned a sapphire pin that matched the sapphire
bracelet valued above and the seized items consisting of the
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