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Enterprises held by The Aukers, Community Developers, Ltd.--
35-percent discount for lack of marketability and lack of
control, (6) the 25.57-percent interest in Eldon L. Auker
Enterprises held by Auker Investments, Inc.--35-percent discount
for lack of marketability and lack of control, and (7) the
20.27-percent interest in Eldon L. Auker Enterprises held by The
Aukers, Community Developers, Ltd.--35-percent discount for lack
of marketability and lack of control.
The estate did not use Mr. Stockdale's values on the
decedent's Federal estate tax return. After receiving
Mr. Stockdale's values, the estate asked its accounting firm of
Rachor, Purman & Tucker, C.P.A.'s (Rachor, Purman), to apply
market absorption discounts in addition to the discounts
ascertained by Mr. Stockdale. Rachor, Purman applied a
15-percent market absorption discount to each parcel of the
subject property, and the estate reported the values ascertained
by Mr. Stockdale, as adjusted by these 15-percent discounts, on
the decedent's Federal estate tax return. The decedent's Federal
estate tax return reported that the applicable value of the
decedent's gross estate for Federal estate tax purposes was
$5,592,994, and that the decedent's taxable estate totaled
$3,968,403. The estate estimated that it would pay Rachor,
Purman a total of $170,000 for their services in accounting for
the estate. Whereas the estate paid Allied Real Estate
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