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timberland, and no such comparables were shown to exist.9
Although there are no truly comparable sales in this record,
the detail available on the Pennzoil transaction does provide
some measure of a contemporaneous arm’s-length transaction. In
the series of Pennzoil transactions the discounts before
acquisition of a controlling interest hovered around 60 percent.
On the basis of that example and the other factors discussed
above, we hold that John’s and Sarah’s fractional interests
should be discounted 60 percent, as claimed by the estates, from
the fair market values agreed to by the parties.
To reflect the foregoing and considering the parties’
agreements,
Decisions will be entered
under Rule 155.
9 It appears that Mr. Steele’s suggested 90-percent discount
may represent only a buyer’s point of view. Perhaps it would
serve as a low bid to initiate negotiations.
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