-74-
sapphire necklace and the sapphire ring. The decedent owned a
ruby pin that matched the ruby bracelet valued above and the
seized items consisting of the ruby necklace and the ruby ring.
We find that the decedent retained ownership of these pins at his
death.
We decide that the fair market values of these sapphire and
ruby pins were the same as the fair market values of the sapphire
bracelet and the ruby bracelet, respectively.45 We find supra
p. 65 that the fair market value of the sapphire bracelet was
$4,400 as of the applicable valuation date. We find supra pp.
65-66 that the fair market value of the ruby bracelet was $5,800
as of the applicable valuation date. Accordingly, we find that
the fair market values of the sapphire and ruby pins were $4,400
and $5,800, respectively, as of the applicable valuation date.
p. Pendants
The May 5, 1988, receipt from Lloyds shows that the decedent
purchased six items from Lloyds at a cost of $235,000. Two of
these items were a sapphire pendant with round diamonds and an
18-kt. gold, ruby, and diamond pendant. The receipt indicates
that the prices of those pendants were $15,000 and $18,400,
45 We decide that the pins are more similar in size to the
bracelets than to the rings.
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