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of Andrews, supra at 956; Buffalo Tool & Die Manufacturing
Co. v. Commissioner, supra at 452; Messing v. Commissioner,
48 T.C. 502, 512 (1967); Furman v. Commissioner, T.C. Memo.
1998-157.
In this case, the parties agree that in valuing the
subject limited partnership interest a minority discount
and a lack of marketability discount must be applied. The
minority discount accounts for a decedent’s lack of control
over the property. See Ward v. Commissioner, 87 T.C. 78,
106 (1986); Harwood v. Commissioner, 82 T.C. 239, 267
(1984), affd. without published opinion 786 F.2d 1174 (9th
Cir. 1986); Estate of Andrews v. Commissioner, supra at
953. The lack of marketability discount accounts for the
fact that there is no ready market for a decedent’s
interest in the property. See Estate of Andrews v.
Commissioner, supra at 953. While the parties agree that
both discounts are appropriate, they disagree about the
amount of each discount, and, thus, they disagree about
the value of the subject limited partnership’s interest.
To establish the value of the subject limited
partnership interest, the parties rely upon the testimony
and report of their respective expert witnesses. The Court
evaluates an expert opinion in light of the demonstrated
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