-33-
factors affecting the potential costs of partitioning the
properties in issue. He considered the time and expense of
selling real property in that particular market. Wiggins
appropriately considered all relevant facts and gave a reasonable
explanation for the discount he applied to the property interests
at issue here.
Respondent's expert, Elmore, applied no discount to
petitioner's and decedent's property interests. He admitted,
however, that an undivided one-half interest in real property has
a limited market and that a fractional interest may be
discounted, although he did not quantify the amount of the
discount. This generally supports petitioners' claim that the
Putnam and Clay County properties and the estate property should
be discounted because they are undivided one-half interests.
d. Whether Petitioners' Property Interests Should Be
Discounted Because of the Purported Partnership
Between Decedent and Petitioner
Petitioners argue that we should discount the Putnam and
Clay County properties by more than 44 percent because decedent
transferred them to petitioner subject to the purported
partnership between decedent and petitioner. We disagree. As
discussed at paragraph II-A-3, above, decedent did not contribute
any property to a partnership, or make any of her property
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