Estate of Etta H. Weinberg - Page 27

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             $800,000 to be the minimum future distributions because the              
             final mortgage payment was to be made in April 1993.                     
                  Third, we agree with respondent’s expert’s use of 16                
             comparables.  Respondent's expert selected 16 comparables                
             and found the midpoint of the returns of those comparables,              
             10.45 percent.  He made three adjustments and arrived at                 
             9.7 percent as the return that an investor would require                 
             from Hill House.  On the other hand, petitioner’s expert                 
             in effect based the yield used in his computation on a                   
             single comparable.  We believe that the use of a single                  
             comparable can be problematic, and we prefer the approach                
             of respondent’s expert in using a number of comparables.                 
             Cf. Estate of Hall v. Commissioner, 92 T.C. 312, 339-340                 
                  As noted above, respondent’s expert did not use the                 
             net asset value approach.  Nevertheless, using the 16                    
             comparables that respondent’s expert selected, it appears                
             that an investor would discount the net asset value of Hill              
             House by 53.4 percent to arrive at the fair market value of              
             the subject limited partnership interest under the net                   
             asset value approach.  We computed this discount using a                 

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