Estate of George A. Lehmann, Deceased, Walter G. Kealy, Jr., Personal Representative - Page 9

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            specific testimony, if it is within the range of figures that may                         
            properly be deduced from the evidence.  Silverman v.                                      
            Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo.                          
            1974-285; Alvary v. United States, 302 F.2d 790, 795 (2d Cir.                             
            1962).                                                                                    
                  The willing buyer-willing seller standard generally is used                         
            in valuing transferred property.  United States v. Cartwright,                            
            supra.  The standard is an objective test using hypothetical                              
            buyers and sellers in the marketplace, and is not a personalized                          
            one which envisions a particular buyer and seller.  Estate of                             
            Andrews v. Commissioner, 79 T.C. 938, 956 (1982); Kolom v.                                
            Commissioner, 71 T.C. 235, 244 (1978), affd. 644 F.2d 1282 (9th                           
            Cir. 1981).  Generally, for estate tax purposes, property is                              
            valued at its fair market value based on its highest and best                             
            use.  Sec. 2031(a); sec. 20.2031-1(b), Estate Tax Regs.                                   
            A.    Respondent's Expert                                                                 
                  Respondent relies upon the report and testimony of an                               
            expert, Richard L. Parli.  Parli is a certified general real                              
            property appraiser.                                                                       
                  Parli considered two methods of estimating the value of                             
            decedent's partial interest in the partnership:  (1) The income                           
            discounting method and (2) the fractional discounting method.                             
            Ultimately, Parli concluded that the fractional discounting                               
            method was the appropriate method because, in his view, land is                           
            not inherently income producing.                                                          




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