Estate of James Barudin, Deceased, Muriel B. Clarke, Executrix - Page 11

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          (1984), affd. without published opinion 786 F.2d 1174 (9th Cir.             
          1986); Mandelbaum v. Commissioner, T.C. Memo. 1995-255, affd.               
          without published opinion 91 F.3d 124 (3d Cir. 1996); Moore v.              
          Commissioner, T.C. Memo. 1991-546.                                          
               Petitioner's and respondent's experts use similar basic                
          steps to value decedent's ownership unit in the FC Partnership.             
          The experts:  (1) Estimate the December 31, 1989, fair market               
          value of the underlying Partnership Properties; (2) convert that            
          value into a partnership liquidation value; (3) divide the                  
          partnership liquidation value by 95 to calculate the liquidation            
          value of decedent’s one ownership unit; and (4) apply their                 
          respective combined minority-interest and lack-of-marketability             
          discounts to the liquidation value of decedent's one ownership              
          unit.                                                                       
               The major points of disagreement between petitioner's and              
          respondent's experts relate to the fair market value of the                 
          underlying Partnership Properties and to the amount of the                  
          discounts to apply that would approximately reflect the minority            
          status and lack of marketability of decedent's ownership unit.              
               The schedule below summarizes each of the experts'                     
          valuations of the underlying Partnership Properties as of                   
          December 31, 1989, the discounts they apply, and their respective           
          ultimate date-of-death valuations of decedent's ownership unit in           
          the FC Partnership:                                                         






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