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was 95 percent uplands and 5 percent wetlands and was some of the
best acreage owned by petitioner and decedent; the Clay County
property transferred to petitioner was 21 percent uplands and 79
percent wetlands. The 329-acre parcel sold was virtually
unregulated by the Water Management District and other
governmental agencies, in contrast to the property transferred
which was almost totally regulated by the Water Management
District, the Army Corps of Engineers, the Florida Department of
Environmental Protection, and the Clay County Planning
Department.
We conclude that the value of a fee simple interest in the
Clay County property was $1,736,250 ($750 per acre) in 1983.
Decedent gave petitioner an undivided one-half interest in the
Clay County property. One-half of $1,736,250 is $868,125. We
discuss at paragraph II-B-5, below, to what extent the Clay
County property should be discounted because petitioner received
an undivided one-half interest in it.
5. Discounts
The applicability and extent of a discount for a fractional
interest is a question of fact to be decided based on the entire
record. Estate of Fawcett v. Commissioner, 64 T.C. 889, 898
(1975); Estate of Campanari v. Commissioner, 5 T.C. 488, 492
(1945). Courts have held that the sum of all fractional
interests can be less than the whole and have used fractional
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