Estate of Albert Strangi - Page 22

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          Valuation of Decedent’s Limited Partnership Interest                        
               For the reasons stated above, resolution of this case                  
          requires that we determine the fair market value of decedent’s              
          limited partnership interest in SFLP.  For reasons stated above             
          and below, we do not believe that the discounts claimed by                  
          petitioner in this case are reasonable.                                     
               Fair market value is the price at which property would                 
          change hands between a willing buyer and a willing seller,                  
          neither being under any compulsion to buy or to sell and both               
          having reasonable knowledge of relevant facts.  See United States           
          v. Cartwright, 411 U.S. 546, 551 (1973); sec. 20.2031-1(b),                 
          Estate Tax Regs.  Under the hypothetical willing buyer-willing              
          seller standard, decedent’s interest cannot be valued by assuming           
          that sales would be made to any particular person.  See Estate of           
          Bright v. United States, 658 F.2d 999, 1001 (5th Cir. 1981).  On            
          the other hand, transactions that are unlikely and plainly                  
          contrary to the economic interest of a buyer or seller are not              
          reflective of fair market value.  See Estate of Curry v. United             
          States, 706 F.2d 1424, 1429 (7th Cir. 1983); Estate of Newhouse             
          v. Commissioner, 94 T.C. 193, 232 (1990); Estate of Hall v.                 
          Commissioner, 92 T.C. 312, 337 (1989); Estate of O’Keeffe v.                
          Commissioner, T.C. Memo. 1992-210.                                          
               The trier of fact determining fair market value must weigh             
          all relevant evidence and draw appropriate inferences.  See Hamm            

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