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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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