- 23 - v. Commissioner, 325 F.2d 934, 938 (8th Cir. 1963), affg. T.C. Memo. 1961-347; Estate of Andrews v. Commissioner, 79 T.C. 938 (1982). Reviewing the facts of this case, at the date of death, decedent owned a 99-percent limited partnership interest in SFLP and a 47-percent interest in Stranco, the 1-percent owner and general partner of SFLP. Approximately 75 percent of the partnership’s value consisted of cash and securities. It is unlikely and plainly contrary to the interests of a hypothetical seller to sell these interests separately and without regard to the liquidity of the underlying assets. SFLP was not a risky business or one in which the continuing value of the assets depended on continuing operations. Each of the parties in this case presented expert valuation testimony. The experts agreed that the appropriate methodology was the “net asset value” approach. Each expert determined and applied a minority interest discount and a marketability discount to the net asset value of the partnership assets. Both petitioner’s expert and respondent’s expert determined that a 25-percent lack of marketability discount was appropriate. Only respondent’s expert, however, considered decedent’s ownership of Stranco stock. We agree with respondent that the relationship between the limited partnership interest and the interest in Stranco cannot be disregarded. The entities werePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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