Estate of Eldon L. Auker, Deceased, Kimberlee J. Auker, Independent Personal Representative - Page 1

                                 T.C. Memo. 1998-185                                  

                               UNITED STATES TAX COURT                                

               ESTATE OF ELDON L. AUKER, DECEASED, KIMBERLEE J. AUKER,                
                         OF INTERNAL REVENUE, Respondent                              

               Docket No. 13150-96.                Filed May 19, 1998.                

                    E's estate includes real estate and interests in                  
               five family-owned entities, the assets of which include                
               real estate and interests in two other family-owned                    
               entities that own real estate.  E's real estate                        
               consists of three apartment complexes.  Collectively,                  
               the entities' real estate consists of commercial rental                
               property, residential rental property, vacant land, and                
               developed property held for sale.  R and E agree that                  
               all the real estate mentioned above must be valued in                  
               order to determine the value of E's gross estate; and                  
               they agree on the value of each parcel of real estate,                 
               before any discount for market absorption; and they                    
               agree that large marketability and control discounts                   
               apply to most of the interests.  R and E dispute                       
               whether a market absorption discount inheres in the                    
               value of E's real estate and the entities' real estate.                
                    Held:  A 6.189-percent market absorption discount                 
               inheres in the value of each apartment complex; none of                

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011