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knowledge, there is no disagreement as to this aspect of the
majority opinion.
Second, the majority opinion values the two gifts made by
petitioner. In the case of the bank stock, the parties
stipulated that before the transfer to the partnership the
aggregate value of the stock of the three banks that was included
in the transfer was $932,219. In view of the fact that the stock
of each of the three banks represented a minority interest in the
bank, the majority reduced or discounted the value of the stock
by 15 percent. This discount was claimed on petitioner’s gift
tax return, and respondent did not contest it in these
proceedings. There is nothing to suggest that the amount of this
discount would vary depending on whether the gifts were valued in
the aggregate or separately. The majority then, in effect,
treats 50 percent of the remaining value as having been retained
by petitioner through his interest in the family partnership and
treats 25 percent of the remaining value, $198,097, as a gift to
each son in accordance with section 25.2511-1(h)(1).
In the case of the leased land, after resolving various
factual disputes between and among the parties’ expert witnesses,
the majority opinion concludes that the present value of the
leased land, before the transfer to the partnership, was
$757,064. In view of the fact that the gifts made by petitioner
were gifts of undivided interests in the leased land, the
majority agrees that the value of the leased land should be
reduced or discounted by 15 percent due to the fact that the
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