Estate of George A. Lehmann, Deceased, Walter G. Kealy, Jr., Personal Representative - Page 7

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            Richard Zitelman of the Zitelman Group, Inc.  Zitelman determined                         
            that, as of the valuation date, the fair market value of                                  
            decedent's interest was $399,000.  Petitioner included this                               
            amount in the gross estate.  Respondent determined the fair                               
            market value of the decedent's interest as of the date of death                           
            was $1,070,000.  Subsequently, respondent conceded $262,000 of                            
            that adjustment.                                                                          
                                              OPINION                                                 
                  We must decide whether petitioner properly valued decedent's                        
            interest in the partnership for purposes of section 2031(a).                              
            Petitioner must prove that respondent's determination of value                            
            set forth in the notice of deficiency is incorrect.  Rule 142(a);                         
            Welch v. Helvering, 290 U.S. 111, 115 (1933); Estate of Gilford                           
            v. Commissioner, 88 T.C. 38, 51 (1987).                                                   
                  The parties agree that decedent's interest should be valued                         
            as a limited partnership interest notwithstanding the fact that                           
            decedent held a 1-percent general partnership interest as of the                          
            valuation date but do not agree upon the value of that interest                           
            or upon the method by which decedent's interest should be valued.                         
            Respondent's expert used the fractional discount method, whereas                          
            petitioner's expert used the discounted cash-flow (DCF) method.                           
                  The parties primarily rely upon their experts' testimony and                        
            reports to support their respective positions.  Expert testimony                          
            sometimes aids the Court in determining valuation.  Other times,                          
            it does not.  See Laureys v. Commissioner, 92 T.C. 101, 129                               




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