- 8 -
942 (1982); Estate of Piper v. Commissioner, 72 T.C. 1062, 1087
(1979); Estate of Robinson v. Commissioner, 69 T.C. 222, 226
(1977); Estate of Cruikshank v. Commissioner, 9 T.C. 162, 165
(1947).6 Moreover, we have also held that a discount to asset
values for the "lost use of money" is inappropriate because it
fails to recognize that the underlying assets will themselves
appreciate, most likely, at a rate similar to that applied as a
discount. Estate of Andrews v. Commissioner, supra at 950.
The seminal case, Estate of Cruikshank v. Commissioner,
supra, held that potential capital gain taxes were not includable
in the computation for a discount in the valuation of certain
corporate shares. In that case, the taxpayer held stock in a
closely held corporation which was an investment holding company.
The parties agreed that the corporation should be appraised on
the basis of the value of its underlying assets. The issue
presented was whether the value of the underlying assets should
be reduced by amounts of commissions and stamp and capital gain
taxes which would become payable if the assets were sold. We
stated:
6See also Estate of Gray v. Commissioner, T.C. Memo. 1997-
67; Estate of Luton v. Commissioner, T.C. Memo. 1994-539; Estate
of Ford v. Commissioner, T.C. Memo. 1993-580, affd. 53 F.3d 924
(8th Cir. 1995); Estate of McTighe v. Commissioner, T.C. Memo.
1977-410; Estate of Thalheimer v. Commissioner, T.C. Memo. 1974-
203, affd. on this issue and remanded without published opinion
532 F.2d 751 (4th Cir. 1976); Gallun v. Commissioner, T.C. Memo.
1974-284.
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