-75-
respectively.46 We find that the decedent retained ownership of
these pendants at his death.
We find that the fair market values of the sapphire and
diamond pendant, on the one hand, and the 18 kt. gold, ruby, and
diamond pendant, on the other hand, were $15,000 and $18,400,
respectively, as of the applicable valuation date.
q. Furniture
The coexecutors valued the decedent’s dining room set at
$1,100 ($800 + $300). We value it supra pp. 41-42 at $17,662.
They valued his curio cabinets at $1,500. We value these
cabinets supra pp. 41-42 at $8,831. They valued his Ming chair
at $50. We value it supra pp. 41-42 at $2,208. The sum of these
three items as valued by us, on the one hand, and by the
coexecutors, on the other hand, is $28,701 ($17,662 + $8,831 +
$2,208) and $2,650 ($1,100 + $1,500 + $50), respectively. We
find as to these items that the coexecutors failed to report
value of $26,051 ($28,701 - $2,650).
46 Of the items listed on the May 5, 1988, receipt, the only
item that did not have a listed price was the “Ivory Maiden”.
The listed prices of the other items on that receipt totaled
$120,900 ($7,500 + $6,000 + $74,000 + $15,000 + $18,400 =
$120,900). We decide that the difference between $235,000 and
$120,900 ($114,100) was paid for the ivory maiden. We decide in
this regard that the ivory maiden was either significantly more
valuable than the other pieces of ivory which we valued at $3,750
apiece or that it was not one piece of ivory but was a multipiece
collection.
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