-32-
contention of value where the Commissioner introduced no evidence
to rebut the taxpayer's expert's testimony).
Respondent argues that Wiggins was not qualified to value
real property because he is a business appraiser and not a real
estate appraiser. Respondent contends that Wiggins provided no
factual basis for his conclusions that a 20-percent discount for
lack of marketability should apply. Respondent points out that
Wiggins included in his report as evidence of the appropriate
amount for marketability discounts a discussion of the
illiquidity of privately held companies and discounts relating to
sales of their stock. Respondent argues that we should give no
weight to Wiggins' opinion because he did not consider the
marketability of real property. Respondent argues that Wiggins'
use of a 30-percent discount for lack of control for the cost of
partitioning the properties was not supported by any verifiable
data in his reports and far exceeds Scruby's estimated costs of
partition.
We disagree that we should disregard Wiggins' report because
he is not a real estate appraiser. Wiggins is an experienced
business appraiser who has given expert opinions in valuing
fractional interests in partnerships, businesses, and real
property. We believe that he correctly considered various
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