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Because the record does not show that a marketability
discount applies to the stipulated value of the Decedent’s CGT
shares, we hold that no discount for marketability is allowable.7
In so holding, we have considered all arguments made by
petitioner, and, to the extent not discussed above, have found
them to be without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
7 Respondent argues that the fact that the Decedent
controlled CGT means that a control premium exists to the extent
of any marketability discount. Based on our holding, we need
not, and do not, address this argument.
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Last modified: May 25, 2011