- 12 - section 6166 election had it been told of the increased estate tax liability. Petitioner also claims that the Chestnut property appreciated in value after its premature sale, and petitioner would have been able to sell it for a higher sum but for the issuance of the closing letter. Again, this involves conjecture. Petitioner has failed to demonstrate that it suffered a detriment as a result of its reliance on the closing letter. We conclude that respondent is not equitably estopped from assessing additional estate taxes. II. Discounts We must now decide the proper amounts of blockage and fractional interest discounts to apply to the Brocato properties. On the return, petitioner applied a 20-percent blockage discount to the Brocato properties and applied an additional 20- percent fractional interest discount to the fractional interest properties. These discounts were based on the Rhoades report. On brief, petitioner continues to claim a 20-percent fractional interest discount on the fractional interest properties but concedes it is entitled only to a 12.5-percent blockage discount on eight properties (excluding 101 Capra). In the notice of deficiency, respondent allowed a blockage discount of $116,627 (approximately 1.92 percent) on seven of the nine Brocato properties and a fractional interest discount on thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011