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reports ostensibly adjusted Mr. Holden's conclusions regarding
the shopping center values in the Holden I reports for changes in
the real estate market during the 6 months between the date of
Mr. Borgatello's death and the alternate valuation date. On the
basis of the Holden II reports, the estate decided to elect the
alternate valuation date.
During the audit of the instant case, the estate provided
respondent with the Holden I and II reports. Later, during
discussions with respondent's Appeals Office, the estate provided
the Appeals officer with two reports by Carlos A. Cardenas
(Cardenas reports) valuing MVN and MVS on the alternate valuation
date. The Cardenas reports were not used in the preparation of
the estate's tax return and were not provided to the Internal
Revenue Service during the audit of the estate. At trial, the
estate did not use the Holden I or II reports or the Cardenas
reports. Instead, the estate used two new appraisals by Mr.
Holden (Holden III reports), which valued MVN and MVS on the
alternate valuation date.
Respondent's valuation of MVN and MVS is based upon two
appraisal reports (in a single bound volume) prepared by David
Marx. Mr. Marx prepared a Limited Summary report in which he
reviewed the Holden I, II, and Cardenas reports and adopted some
background data and conclusions from those reports. In
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