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Historically, undivided fractional interests in property
included in an estate have been valued at a discount to reflect
lack of marketability and minority interest holdings. See Estate
of Andrews v. Commissioner, 79 T.C. 938, 952-953 (1982) (minority
interests); Estate of Piper v. Commissioner, 72 T.C. 1062, 1084-
1086 (1979) (marketability discount). Respondent, however, has
long opposed such discounts and has argued for unity of ownership
principles in estate tax cases. See, e.g., Estate of Bonner v.
United States, 84 F.3d 196, 198 (5th Cir. 1996); Propstra v.
United States, supra at 1251; Estate of Bright v. United States,
658 F.2d 999, 1001 (5th Cir. 1981); Estate of Andrews v.
Commissioner, supra at 952-956. Specifically, respondent has
argued that a decedent's fractional interest in property should
be aggregated with fractional interests owned by family members
in the same property for purposes of valuing the property in the
estate. Propstra v. United States, supra at 1251; Estate of
Bright v. United States, supra at 1001; Estate of Andrews v.
Commissioner, supra at 952. Respondent's basis for this position
was that such undivided fractional interests should be valued by
taking into consideration family cooperation and the likelihood
that fractional interests will be sold together rather than
separately. See Propstra v. United States, supra at 1251; Estate
of Andrews v. Commissioner, supra at 952. Respondent relied on
this argument despite section 20.2031-1(b), Estate Tax Regs.,
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