- 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.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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