Estate of Vera M. McFarland, Deceased, Jo Meldrim, Personal Representative - Page 4

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               On September 22, 1991, Decedent died leaving her 20-percent            
          interest in the Partnership in trust.  In connection therewith,             
          her will stated:                                                            
               My said executrix and trustee is hereby given full                     
               authority and power * * * to continue and carry on any                 
               business in which I am engaged at the time of my death,                
               including the continuation of any partnership in which                 
               I may be interested at the time of my death,                           
               particularly the partnership with my said brother, J.S.                
               Meldrim, and that to facilitate the uninterrupted                      
               continuance of said partnership operation, my said                     
               executrix and trustee is hereby designated a                           
               substituted partner in said partnership, if deemed                     
               desirable by said executrix and trustee, for and during                
               the administration of my estate and said trust; * * *                  
               When Decedent died, the Partnership owned 5,501 acres of               
          land and timber in St. John's County, Florida, along with other             
          assets.  On petitioner's Form 706, United States Estate Tax                 
          Return, Personal Representative reported that the fair market               
          value of Decedent's 20-percent interest in the partnership                  
          equaled $533,895.  Upon audit, respondent determined that the               
          fair market value was $1,147,177.  Respondent valued the                    
          20-percent interest by:  (1) Valuing the Partnership's land and             
          timber by reference to comparable sales, (2) adding 20 percent of           
          this value to 20 percent of the fair market value of the other              
          assets of the partnership as reported on Form 706, (3) applying a           
          10-percent discount to take into account Decedent's fractional              
          interest in the Partnership, and (4) applying a 15-percent                  
          discount to reflect other factors such as the lack of                       
          marketability.                                                              





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