- 62 -
analyses must incorporate our finding as to the aggregate fair
market value on that date of the remaining unimproved real
properties of Marrero Land. We have incorporated that finding
into the respective valuation analyses of Mr. Chaffe and Mr.
Stryker, which results in a fair market value on the valuation
date of decedent's interest in Marrero Land of $4,611,417 under
Mr. Stryker's analysis and $4,000,328 under Mr. Chaffe's analy-
sis. On the instant record, we find that those values set the
appropriate range from which we may determine the fair market
value of that interest on that date.
Based on our examination of the entire record in this case,
and bearing in mind that valuation is necessarily an approxima-
tion and a matter of judgment, rather than of mathematics, see
Estate of Davis v. Commissioner, 110 T.C. at 560, on which the
estate has the burden of proof, see Rule 142(a), we find that on
the valuation date the fair market value of decedent's interest
in Marrero Land is its book value, i.e., $4,316,920.23
22(...continued)
relating to the estate's stock valuation experts that are not
addressed herein, and we find them to be without merit.
23Because the fair market value of decedent's interest in
Marrero Land on the valuation date that we have found does not
exceed the book value of that interest (i.e., $4,316,920) de-
termined under amended article VI, we shall not address the
estate's alternative position that, because amended article VI
controls the fair market value for estate tax purposes, the
(continued...)
Page: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 NextLast modified: May 25, 2011