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one share applies equally to every other share in that class. In the
case of real estate, however, a different rule applies. No two
parcels of real estate are the same. Thus, the application of a
single discount to various parcels of dissimilar real estate, which
by its very nature ignores the uniqueness of each parcel, is usually
inappropriate. See Estate of O'Keeffe v. Commissioner, T.C. Memo.
1992-210 (same rationale applied to works of art). Single rates of
discount apply to each group of essentially similar assets.
We analyze the assets at hand. When he died, the decedent owned
the apartment buildings and various interests in numerous entities
that owned real estate or interests in other entities that owned real
estate. The estate and Mr. Shanker ask us to look through the
various interests that the decedent owned at the time of his death
and conclude that the decedent owned 58 parcels of real estate. This
we will not do. The decedent structured his business affairs so that
the subject property was owned by various entities, rather than by
him personally. We will not now disregard the separate entities and
treat the decedent as owning all the subject property. Because the
entities were viable going concerns on the applicable valuation date,
and neither a sale nor a liquidation of the entity-owned real estate
was contemplated at that time, we conclude that the entity-owned real
estate is ineligible for a market absorption discount. See, e.g.,
Estate of Andrews v. Commissioner, 79 T.C. 938, 942 (1982), and the
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