Estate of George A. Lehmann, Deceased, Walter G. Kealy, Jr., Personal Representative - Page 13

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            market value to decedent's interest in the partnership of                                 
            $399,000.                                                                                 
                  The divergent methodologies of the experts that testified in                        
            this case reveal that the determination of the value of a                                 
            minority interest in a partnership holding real estate is a                               
            matter of judgment to be resolved on the basis of the entire                              
            record.  See Estate of Lauder v. Commissioner, T.C. Memo. 1994-                           
            527.  Parli failed to explain adequately how he derived the                               
            individual discounts.  Rather, Parli summarily concluded that                             
            each individual discount is "typical" without providing any                               
            evidence, e.g., comparables or market data, establishing the                              
            basis of these conclusions.  Giving due consideration to each of                          
            the expert reports, and weighing all of the facts and                                     
            circumstances presented, we conclude that Zitelman's methodology                          
            provides the most reliable basis for valuing the decedent's                               
            interest as of the valuation date.  The value of any interest in                          
            real property that has an income stream can be estimated by the                           
            DCF method.  See Estate of Bennett v. Commissioner, T.C. Memo.                            
            1993-34; Estate of Hatchett v. Commissioner, T.C. Memo. 1989-637.                         
            The evidence before the Court shows that the property had a                               
            determinable income stream.                                                               
                  Respondent concedes that the DCF method is an appropriate                           
            appraisal method in some contexts but argues that, based upon                             
            Parli's testimony, the method is not appropriate when the current                         
            use of the property is not its highest and best use.  Respondent                          




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