Estate of James Barudin, Deceased, Muriel B. Clarke, Executrix - Page 12

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          Valuation of Partnership                Petitioner's   Respondent's         
          Properties Before Discounts:            Expert         Expert               
             Estimated Gross Annual Lease Income  $15,082,200    $16,345,491          
             Contingency Loss Reserve                  5%             1%              
             Operating Expenses                   $6,650,193     $6,920,501           
             Estimated Annual Lease Income        $8,432,007     $9,424,990           
             Capitalization Rate                  8.5%                7.9%            
             FMV of Partnership Properties        $100,000,000   $120,000,000         
             Less Partnership Liabilities         $41,595,787    $41,595,787          
             FC Partnership Net Liquidation Value $58,404,213    $78,404,213          
             Per-Unit Liquidation Value           $614,781       $825,307             
          Discounts For:                                                              
             Minority Interest                    --                  15%             
             Lack of Marketability                     --             15%             
             Combined Discount                    67.5%               28%             
          FMV of Decedent's Ownership Unit:       $200,000       $594,221             

               In estimating gross annual lease income of $15,082,200,                
          petitioner's expert takes into account lease income received from           
          comparable properties in Midtown South and leases executed by the           
          FC Partnership proximate in time to December 31, 1989.  In                  
          estimating operating expenses of $6,650,193, petitioner's expert            
          considers operating expenses in prior years, operating expenses             
          of comparable buildings, and various market studies.  Taking into           
          account a 5-percent contingency loss for vacancies and                      
          noncollection of rent and the above-estimated operating expenses,           
          petitioner's expert estimates annual net lease income from the              
          properties of $8,432,007.                                                   
               Petitioner's expert then capitalizes estimated annual net              
          lease income by an 8.5-percent capitalization rate, which                   
          provides a fair market value for the Partnership Properties of              






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