Ina F. Knight - Page 3




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               2.   Whether, as petitioners contend, the fair market value              
          of petitioners’ gifts is the value of the assets in the                       
          partnership reduced by portfolio, minority interest, and lack of              
          marketability discounts totaling 44 percent.  We hold that                    
          discounts totaling 15 percent apply.                                          
               3.  Whether the fair market value of each of petitioners’                
          gifts to each children’s trust on December 28, 1994, is $263,165              
          as petitioners contend, $450,086 as respondent contends, or some              
          other amount.  We hold that it is $394,515.                                   
          4.   Whether section 2704(b) applies.  We hold that it does                   
          not.                                                                          
               Unless otherwise indicated, section references are to the                
          Internal Revenue Code.  Rule references are to the Tax Court                  
          Rules of Practice and Procedure.  References to petitioner are to             
          Herbert D. Knight.  References to Mrs. Knight are to petitioner               
          Ina F. Knight.                                                                
                                   FINDINGS OF FACT                                     
               Some of the facts have been stipulated and are so found.                 
          A.   Petitioners                                                              
               1.   Petitioners’ Family                                                 
               Petitioners were married and lived in San Antonio, Texas,                
          when they filed their petitions and at the time of trial.  They               
          have two adult children, Mary Faye Knight (Mary Knight) and                   
          Douglas Dale Knight (Douglas Knight).  Petitioners’ children were             






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