- 19 -
Income Market
Unadjusted Value $8,109,000 $10,410,000
Less Marketability
Discount:
Nonenvironmental 20% (1,621,800) 20% (2,082,000)
Environmental 10% ( 810,900) 0%
Add Control Premium 25% 2,027,250 1 0%
Fair Market Value of
100 percent Interest 7,703,550 8,328,000
x Decedent's
Interest 81.93% 6,311,519 81.93% 6,823,130
x Weight Given 50% 50%
3,155,759 + 3,411,565 =
Fair Market Value of
Decedent's Interest 6,567,324
1 See supra note 6.
II. Value of Real Properties
A. Generally
On decedent's estate tax return, petitioner reported that on
the alternate valuation date the fair market values of the Newport
property and the Indian Wells property were $800,000 and $280,000,
respectively. Within 20 months of the alternate valuation date,
both properties were sold for amounts less than the fair market
values reported on decedent's estate tax return. Petitioner claims
that the fair market values for the Newport property and the Indian
Wells property should be $699,933 and $267,782, respectively, based
on their actual sales prices.
Values submitted by a taxpayer on the estate tax return are
admissions by the taxpayer, and lower values cannot be substituted
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