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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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