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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 the
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