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length sale of Waldorf's interest to Darlene Wiltzius or any
risks associated with the note. Shelton believed that repayment
of the note had no more than average risk. We disagree; we
believe that substantial risks were associated with the House of
Babes note. We discount the note by 25 percent because of those
risks.
Petitioners cited several cases in support of their position
relating to the value of the note. Nothing in those cases leads
us to alter our conclusions here. Although prior decisions can
be helpful in deciding a valuation issue, we primarily decide the
value of property based on the facts and circumstances of each
case. Riss v. Commissioner, supra; Estate of Johnson v.
Commissioner, supra.
3. Conclusion
We conclude that Wiltzius and Waldorf are liable as
transferees up to the value of the cash that they each received
from the sale of the assets of House of Babes plus the value of
the interest of each in the note. The value of Wiltzius' 22.5-
percent share of the note is $88,593.75 ($118,125 x .75). The
value of Waldorf's 32.5-percent share of the note is $127,968.75
($170,625 x .75).
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