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as to the valuations of those entities for Federal estate tax
purposes, which valuations the parties have stipulated are
correct. Accordingly, we conclude that the accounts receivable
of the housing partnerships should be valued at face value, and
we make no adjustment to Beck’s report in this respect.13
(b) Trust Fund Accounts
Beck assigned no value to the trust funds established and
maintained under the financing arrangements of the housing
partnerships, on the grounds that maintenance of the funds was
essentially a prerequisite for the HUD subsidies and therefore
the funds were not available to a purchaser of decedent’s
interest. It is respondent’s contention that the trust funds are
includable in the net asset value of the partnerships at their
full face value as of December 31, 1989. Although we disagree
with respondent’s approach, we also do not believe that Beck has
fully accounted for the value supplied by the trust funds. We
13 Petitioner also argues with respect to Godley Realty
that its accounts receivable were not actually accounts
receivable; that is, petitioner argues that they were not amounts
owed by Godley Realty to each housing partnership but rather were
distributions from Godley Realty, before it was incorporated, to
decedent and Fred Jr. and were incorrectly recorded as
receivables held by the housing partnerships. We reject this
argument for a number of reasons. First, the supporting evidence
is at best vague and imprecise. Second, in contradiction to this
position, petitioner submitted an expert report that treated
these amounts as accounts receivable. Finally, petitioner
allowed respondent to treat the corresponding amounts as accounts
payable in the hands of Godley Realty, which resulted in their
treatment as liabilities at face value when respondent and
petitioner reached agreement on the valuation of Godley Realty.
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