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(6) 2000 Beach Street, an 18-unit apartment building
(2000 Beach)
(7) 101 Capra Way, a 15-unit apartment building,
wherein decedent owned a 50-percent interest
(101 Capra)
(8) 3737 Fillmore Street, a 15-unit apartment
building, wherein decedent owned a 50-percent
interest (3737 Fillmore)
(9) 1359-61 Bay Street, a duplex house, wherein
decedent owned a 50-percent interest (1359 Bay)
All of the above properties are located in the Marina District of
San Francisco, California. The Marina District is one of several
desirable districts in which to reside in San Francisco. The 101
Capra, 3737 Fillmore, and 1359 Bay properties (collectively, the
fractional interest properties) were held by decedent and Mr.
Brocato as tenants in common during their lives, each owning a
50-percent interest.
The parties agree that the values of decedent’s interests in
the nine properties before applying discounts are as follows:
(1) 25 Cervantes $1,640,000
(2) 3637 Fillmore 1,293,000
(3) 2395 Francisco 1,058,000
(4) 15 Alhambra 914,000
(5) 2360 Chestnut 2,875,000
(6) 2000 Beach 1,173,000
(7) 101 Capra 619,000
(8) 3737 Fillmore 593,000
(9) 1359 Bay 267,000
Total 10,432,000
The Closing Letter
On the return filed June 30, 1994, petitioner reported the
value of the Brocato properties based on an appraisal report by
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