- 43 -
Accordingly, on the basis of our review of all the expert
testimony and reports, we conclude and hold that Dilmore’s 15-
percent valuation discount for an undivided fractional interest
in the leased land is fair and reasonable.28
2. The Bank Stock
With regard to the bank stock, respondent has not contested
the 15-percent minority interest discount as claimed on
petitioner’s gift tax return. Accordingly, we hold that the
stipulated value of the bank stock on the date of petitioner’s
gifts ($932,219) is subject to a 15-percent minority interest
discount for the gifts to his sons of undivided interests.
F. Summary and Conclusion
On the basis of all the evidence in the record, we conclude
and hold that petitioner made separate gifts to each of his two
sons of 25-percent undivided interests in the leased land and the
bank stock. The value of the total separate gifts to each son is
28 On brief, petitioner argues that because Lipscomb (and by
extension Dilmore) selected valuation discounts based upon a 50-
percent undivided interest in the leased land, as opposed to a
25-percent undivided interest, their recommended valuation
discounts are understated. Petitioner also argues that various
other cases have allowed fractional-interest discounts greater
than those recommended by petitioner’s own experts. We must
determine the applicable valuation discount on the basis of the
facts in the record before us. Here, petitioner has presented no
concrete, convincing evidence as to what additional amount of
discount, if any, should be attributable to a 25-percent
undivided interest as opposed to a 50-percent undivided interest.
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