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concluded that a discount of 10 percent was appropriate for
parcels 5 and 10, of which decedent owned 51-percent interests.
For parcel 6, of which decedent owned a 50-percent interest, Mr.
Hamel concluded that a 15-percent discount was appropriate.
We do not agree with Mr. Hamel’s conclusions regarding the
appropriate discount, because we disagree with his inclusion of
certain data in his analysis. Some of the purportedly comparable
sales of partial interests, such as the sale that indicated a 4-
percent discount, resulted in the purchaser’s owning a 100-
percent interest. A buyer consolidating all the fractional
interests is likely to pay a premium for those interests. Such a
sale does not indicate the appropriate discount applicable
between the hypothetical willing buyer and willing seller for a
partial interest. Inclusion of those sales skewed Mr. Hamel’s
analysis; as a result we find Mr. Gilman’s conclusions regarding
the appropriate discount more reliable.
Ultimately, we find the conclusions in Mr. Hamel's report to
be questionable, in light of the analytical flaws mentioned
above. Mr. Hamel’s use of data was incomplete and his
conclusions, therefore, suspect.
D. Conclusions Regarding Fair Market Value
Recognizing that valuation is not an exact science, see
Messing v. Commissioner, 48 T.C. 502, 512 (1967), and selecting
those portions of each expert's report that we found helpful, see
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