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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
(1989).
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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