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Parli first determined the present value of the rents due
pursuant to the terms of the ground lease and from the
partnership's reversionary interest in the land and then
calculated decedent's pro rata share of those amounts. Under
Parli's calculations, the present value and decedent's pro rata
share were $4,680,000 and $1,154,043, respectively.
Parli next considered factors affecting the value of
decedent's pro rata share including, inter alia: (1) Relative
risk of the partnership's assets; (2) historical consistency of
the partnership's earnings; (3) condition of the partnership's
assets; (4) market growth potential; (5) portfolio
diversification; (6) strength of management; (7) size of
decedent's interest; (8) liquidity; (9) potential ability to
influence management and (10) relative ease of analyzing the
partnership's assets. Parli assigned individual discounts for
each factor and calculated an aggregate discount factor of 30
percent. Based upon such a discount factor, he assigned a value
to decedent's interest of $808,000.
B. Petitioner's Expert
Petitioner relies upon the report and testimony of its
expert, P. Richard Zitelman. Zitelman is the president of The
Zitelman Group, a firm providing investment advisory and
investment services.
Zitelman also considered two methods of evaluating the fair
market value of decedent's interest: (1) The liquidation method,
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