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in each case must be determined ad hoc, and the facts in each
case must provide the basis for the proper amount of discount.
The facts in this case, along with our understanding of the
actual marketplace, reflect that fractional interests in rural
Louisiana timberland sell at substantial discounts and, hence,
the estate’s reporting positions were conservative in their
approach to discounting.
Conclusion
After considering the record and the experts’ reports and
testimony, we hold that the estates have established 55 percent
as a mean and/or average amount by which fractional interests in
Louisiana timberland which do not result in control are
discounted. We are also convinced that the peculiar
circumstances shown to exist with respect to the decedents’
remaining family members support an increased discount.
We have placed reliance in Mr. Steele’s expertise and actual
practical experience. His report and testimony were based on his
personal knowledge and experience in the very marketplace under
consideration. Mr. Steele’s “at least 55-percent discount” in
his written report comported with the other experts’ findings and
conclusions. Mr. Steele’s trial testimony suggesting a 90-
percent discount, however, was unfounded and without support in
the record. We find it hard to accept that a willing seller
would accept 10 cents on the dollar for a partial interest in
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