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3. Partial Interest Discount
Both parties agree that a partial interest discount is
appropriate in this case. Their positions differ only as to the
size of the discount. For parcels 5 and 6, we find that a 15-
percent partial interest discount is warranted. As discussed
above, in calculating the appropriate amount of the partial
interest discount, we found the calculations of petitioner’s
expert more helpful and reliable than those of respondent’s
expert. Accordingly, we have used the discounts suggested by
petitioner’s expert in reaching our conclusion.15 See Parker v.
Commissioner, supra at 562; Buffalo Tool & Die Manufacturing Co.
v. Commissioner, 74 T.C. at 452.
4. Calculation of the Fair Market Value of Decedent’s
Interests
We calculated the fair market values of decedent’s interests
in parcels 5, 6, 9, and 10 in accordance with the following
formula:
No. of FMV Decedent’s Partial interest
Parcel acres X per acre X pro rata interest X discount = Total
5 1,487 $900 .51 .85 $580,153
6 648 900 .50 .85 247,860
9 90 900 1.00 1.00 81,000
10 7 250 1.00 1.00 1,750
15Respondent’s expert also concluded that decedent’s 50-
percent interest in parcel 6 warranted a 15-percent partial
interest discount.
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