- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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