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half. This rate represents continued moderate growth but is
below that normally experienced in postrecessionary years.
Nondurable goods expenditures advanced 5.9 percent in 1992 after
falling 5.6 percent in 1991.
The California marketplace did not experience the rebound
seen in the majority of the nation in 1992. Its economy
continued to be impacted negatively by defense industry layoffs
and a declining housing market. The Wall Street Journal reported
that the California economy was expected to continue to trail far
behind the rest of the United States in 1993.
ULTIMATE FINDINGS OF FACT
The fair market value of FOH shares includable in decedent's
gross estate should reflect a 25-percent discount for lack of
marketability. On the valuation date, the fair market value of
each of the two 27.8671-percent interests in FOH that were held
by the trusts was $12,802,705, or $5.2031 per share.
OPINION
Issue 1
Section 2031 generally provides that the value of a
decedent's gross estate includes the value of property described
in sections 2033 through 2044. See sec. 20.2031-1(a), Estate Tax
Regs. Under section 2033, the value of a decedent's gross estate
includes the value of all property beneficially owned by the
decedent at the time of death. See sec. 20.2033-1(a), Estate Tax
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