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percent and 11 percent, such as those that petitioner’s experts
used, are supported by the national real estate investors’
surveys at the time of decedent’s death. Furthermore,
petitioner’s experts did not attempt to manipulate rates to
produce inconsistent, yet favorable, discounts on income and loss
from the same period within a single valuation method. For these
reasons, we sustain petitioner’s reported fair market value and
hold that the value of the Kmart property at the date of
decedent’s death was $5,300,000.
Discounts
Discounts to the fair market value of property may be
appropriate to reflect a lack of control and/or a lack of
marketability. A lack of control is the inability to change
corporate or business attributes. See Estate of Casey v.
Commissioner, T.C. Memo. 1996-156. The owners here are all
family members, but it cannot be assumed that a family will
always act as a unit in matters regarding the property. See
Citizens Bank & Trust Co. v. Commissioner, 839 F.2d 1249, 1253
(7th Cir. 1988). Generally, there is no ready market for a
partial interest in a closely held property and that lack of
marketability causes a reduced liquidity. See Estate of Casey v.
Commissioner, supra. The need for employing a discount is
dependent on whether a decedent’s partial interest would affect
the marketability of a property. See Propstra v. United States,
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