Estate of Etta H. Weinberg - Page 24

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             subject limited partnership interest as computed under both              
             the net asset value and the capitalization approaches.  We               
             also agree with petitioner that a weighted average of 75                 
             percent for the capitalization approach and 25 percent for               
             the net asset value approach adequately reflects the                     
             attributes of this partnership.                                          
                  In Estate of Andrews v. Commissioner, 79 T.C. 938                   
             (1982), we considered the value of the decedent’s stock in               
             four closely held corporations, each of which was engaged                
             principally in the ownership, operation, and management                  
             of commercial real estate properties.  In valuing the                    
             decedent’s 20-percent stock interest in each of the                      
             corporations, the parties differed over the weight to be                 
             given to earnings and to the net asset value of the                      
             corporations.  The taxpayer argued that the corporations                 
             should be characterized as operating companies and greater               
             weight should be placed on earnings and dividend-paying                  
             capacity than on net asset values.  See id. at 944.  The                 
             Commissioner argued, contrary to the Government’s position               
             in this case, that the corporations were in the nature of                
             investment companies and would be valued by a hypothetical               
             investor based upon a buyer’s right to share in the value                

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