- 11 - (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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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