- 24 -
five years. See id. One of respondent's experts in Estate of
Andrews performed an appraisal of the assets held by those
corporations. See id. at 941. In the case of the real estate
assets, that expert used the following three methods of val-
uation: Comparable sales, replacement costs, and income-pro-
ducing capacity. After correlating the values found under each
of those methods, respondent's expert in Estate of Andrews
arrived at values for the respective assets held by the four
corporations in which the decedent there involved owned certain
shares of stock. See id. at 941-942. Although the estate in
Estate of Andrews v. Commissioner, supra, did not attack the
valuations by respondent's expert of the underlying assets of the
four corporations in question, it
argued that in arriving at overall net asset value,
adjustments should have been made to reflect costs that
would have been incurred if the corporations had liq-
uidated all their real estate properties and placed
them on the market at one time. The adjustments sought
by petitioner are for blockage [i.e., absorption dis-
count], capital gains tax to the seller, real estate
commissions, and real estate taxes and special assess-
ments constituting a lien against the real estate.
* * *
We rejected the foregoing argument of petitioner in Estate
of Andrews v. Commissioner, supra. We held: "When liquidation
is only speculative, the valuation of assets should not take
these costs into account because it is unlikely they will ever be
incurred." Id. In so holding, we relied on the parties' agree-
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