Estate of Fred O. Godley, Deceased, Fred D. Godley, Administrator CTA - Page 46




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          (i) That Kaye valued the partnership as a whole, rather than                  
          decedent’s interest, and that discounts for lack of control and               
          lack of marketability apply; and (ii) that the fact that GMA’s                
          value depended on the value of the housing partnerships should be             
          taken into consideration.  With respect to discounts, we apply                
          the same discounts, and for the same reasons, that we applied in              
          the case of the housing partnerships.  Respondent concedes a lack             
          of marketability discount of 15 to 20 percent with respect to                 
          GMA, petitioner has not demonstrated that a greater discount                  
          applies, and we accordingly apply a discount of 20 percent for                
          lack of marketability.  Further, petitioner has not demonstrated              
          that a minority interest discount applies, given that Fred Jr.                
          and decedent each held 50-percent partnership interests, and                  
          there is no evidence that Fred Jr. controlled GMA to a greater                
          extent than the housing partnerships.16                                       
               With respect to whether Kaye’s valuation approach took into              
          account the relationships between GMA and the housing                         
          partnerships, we believe it did.  Kaye was aware of the                       
          relationship, and he knew that GMA’s income consisted of accounts             
          receivable generated by the management fees, equal to 10 percent              
          of rental income, paid by the housing partnerships.  Moreover,                
          Kaye’s approach used actual income figures of GMA.  We believe                




               16  The partnership agreement of GMA is not in the record.               




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