Estate of Ruth J. Casey, Deceased, First Interstate Bank of Nevada, Special Administrator - Page 9

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          was not a “going concern”.  Instead, respondent’s expert opined             
          that a willing buyer would be concerned with the question of                
          liquidity because of the time required to liquidate Residence.              
          Accordingly, respondent’s expert concluded that the agreed fair             
          market value should simply be adjusted or discounted for the time           
          value of money (i.e., the delay in realizing the liquidation                
          value of the assets).                                                       
               Respondent’s expert used the May 1990 short-term Treasury              
          rate of 7.8 percent and added a 2.2-percent premium to account              
          for the lapse of time, arriving at a 10-percent discount rate.              
          Respondent’s expert noted that the long-term home mortgage rate             
          was a comparable 10.3 percent during the same time period.  Based           
          on comparable properties, respondent’s expert calculated a 12.4-            
          month mean and 10-month median of time on the market.  Using this           
          information, respondent’s expert arrived at a range of 9.5 to 11            
          percent for the discount and a value range of $7,355,141 to                 
          $7,478,238.                                                                 
               Petitioner, citing Propstra v. United States, 680 F.2d 1248            
          (9th Cir. 1982), argues that a control discount applies because             
          the liquidating trust is no different from a business entity                
          holding property, and because decedent lacked control over the              
          property because she owned less than a majority interest.                   
          Respondent agrees that the discount principles of Propstra v.               
          United States, supra, would apply in a case where the property in           
          question was used in a business.  Respondent also agrees that               




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