-30-
little weight to the fact that Moses did not discount the
property interests at issue here because petitioner retained him
to value the fee simple interests in the properties, not
petitioner's or decedent's undivided one-half interests in the
properties.
b. Whether the Discount Should Be Limited to Scruby's
Estimate of the Cost of Partitioning the Property
Interests
Respondent points out that respondent's 5-percent discount
equals $41,300 (2,360 acres x $350 x .05) for the 1980 gift and
$52,087.50 (2,315 acres x $450 x .05) for the 1983 gift.
Respondent argues that we should not apply a discount greater
than 5 percent because the 5-percent discount is greater than
petitioners' expert's, Scruby's, estimate of the costs of
partitioning the properties. We disagree. First, Wiggins
estimated that partition costs here would be substantially more
than respondent's 5-percent discount, that is, $164,400 for the
Putnam County property, $172,500 for the Clay County property,
and $76,500 for the estate property. Second, respondent's 5-
percent discount does not give adequate weight to other reasons
for discounting a fractional interest in real property, such as
lack of control and the historic difficulty of selling an
undivided fractional interest in real property, discussed below.
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