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On decedent's estate tax return, petitioner excluded one-
half of the value of the Young Property, claiming decedent's
property interest in the Young Property was in the nature of
community property. Petitioner also claimed a fractional
interest discount of 15 percent on the Young Property, citing
Propstra v. United States, 680 F.2d 1248 (9th Cir. 1982).
Respondent determined that petitioner was not entitled to the
fractional interest discount. The following table shows the
value of each Young property less the proportion of value
excluded from the gross estate as stated by petitioner and as
determined by respondent.
PROPERTY Petitioner's Respondent's
Calculations Determination
Value of Property Value of Property
(1)Bixby $565,000 $508,500
Knolls Hotel
(2) Condo- 193,000 193,000
Monterey
Park
(3) Oak Tree 3,300,000 3,300,000
Inn
(4) Condo- 160,000 160,000
El Monte
(5) House in 555,000 570,000
Hacienda
Heights
Less: 1/2 Community Interest 1/2 Interest
Less: Propstra Discount of None
15%
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Last modified: May 25, 2011