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Mr. Young also discussed other factors that might affect the
amount of the discount, such as tract size, lack of management
control, the number of coowners, and the cost of acquiring a fee
interest. He did not, however, provide any guidance as to how
those factors should be taken into account in valuing the 16
parcels of timberland under consideration.
Although the six sales of timber properties cited by Mr.
Young occurred in northwest Louisiana, respondent contends that
there has been no correlation to the 16 parcels of timberland we
consider in these cases. In addition, respondent points out that
Mr. Young, in his discussion of the practicality of partition,
assumed that the partition would result in 65 shares. That
assumption tends to exaggerate the cost of partition.
With respect to Mr. Young’s comparables, respondent provided
some information about each reflecting that the fee value used by
Mr. Young could be too high. Any reduction in the fee value used
would accordingly and proportionately reduce the percentage
discount that could be attributable to a fractional interest.3
3 Mr. Young also provided a report in which he commented on
various assumptions that had been provided by the estates’
counsel. It was not evident how Mr. Young’s comments were
formulated and why he would be qualified to opine on certain of
the assumptions. Accordingly, we do not rely on his commentary
concerning the estates’ assumptions.
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